The recent Go City decision unexpectedly delved into HMRC’s internal procedures and inadequate disclosure as much as the technical difference between a ticket and a voucher. The First-tier Tribunal found that HMRC did not have a clear view that the taxpayer’s VAT return was incorrect, making the first two assessments invalid. It also confirmed that HMRC cannot issue unreasoned assessments simply to extend their time limits as this is not a true protective assessment. The decision provides insight into HMRC’s decision-making process and is likely to increase challenges to HMRC VAT assessments.
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The recent Go City decision unexpectedly delved into HMRC’s internal procedures and inadequate disclosure as much as the technical difference between a ticket and a voucher. The First-tier Tribunal found that HMRC did not have a clear view that the taxpayer’s VAT return was incorrect, making the first two assessments invalid. It also confirmed that HMRC cannot issue unreasoned assessments simply to extend their time limits as this is not a true protective assessment. The decision provides insight into HMRC’s decision-making process and is likely to increase challenges to HMRC VAT assessments.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
