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How Do I Prove That I Did Not Know What I Did Not Know?

Hartley Foster and Sinead Reid DLA Piper comment on HMRC's 'new' approach to MTIC fraud
Press reports suggest that up to 1 000 traders in the mobile phone and computer chip industries have recently been informed that their claims for repayment of input VAT will not be made until an 'extended verification'2 exercise has been completed by HMRC and it is determined that they neither knew nor had any means of knowing of any fraud committed within their supply chains. In their recent article in the The Tax Journal (Issue 848 31 July 2006) Jason Collins and Ben Cooper of McGrigors Solicitors 3 consider that justification for this 'new' approach is to be found in the decision of the European Court of Justice (ECJ) in Axel Kittel and...

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