In M El-Baghdadi v HMRC [2017] UKFTT 171 (13 February 2017) the FTT found that HMRC had been entitled to raise an assessment in circumstances where during a visit of the taxpayer’s premises he had brought its attention to the relevant supplies.
The case related to land owned by the appellant. He had granted a company a licence to occupy the land for a period of five years for the purpose of its business and received £2 000 per week under the licence agreement. HMRC contended that the exemption for supplies of land (VATA 1994 Sch 9 Group 1 item 1) did not apply as the supplies fell within the exception of holiday accommodation.
The appellant submitted that during a visit by HMRC he voluntarily disclosed the income received under the licence agreement explaining that he and his accountants were unsure as to how...