The rules for determining exactly when you make your supply can determine whether HMRC is out of time to assess you for VAT. The case of Mark Reid (and his alter ego Reid & Co) is an interesting study about whether a ‘trigger’ for a tax point – payment – has occurred.
The case of M Reid (practising as Reid & Co Solicitors) v HMRC (TC02655) concerned a supply which may have been exempt from VAT but proceeded on the assumption it was taxable. Mr Reid provided consultancy services and legal services to several related companies. It appears he was referred to as ‘Mark Reid’ for consultancy services and ‘Reid & Co’ (his sole proprietorship) for legal services (though this practice was not consistently applied). There was no legal distinction between Mr Reid...
