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Nottingham Forest Football Club Ltd v HMRC

In Nottingham Forest Football Club Ltd v HMRC [2024] UKUT 145 (TCC) (22 May 2024) the Upper Tribunal (UT) rejected an appeal against a First-tier Tribunal (FTT) decision holding that an HMRC VAT assessment was made not out of time under the one-year evidence of facts rule.

The club was issued with a VAT assessment following a period of discussion with HMRC around errors in figures that had arisen innocently from a change in its accounting systems. This assessment was appealed on the basis that it was raised more than one year after HMRC received evidence of facts which were sufficient to make the assessment.

The case centred on time limit rules in VATA 1994 s 73(6) which require HMRC to make a VAT assessment within the later of:

  • two years after the end of the prescribed accounting period; or
  • one year after evidence of facts sufficient in the opinion of...

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