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Sammy Garden Ltd v HMRC

VAT payable from effective date of registration

In Sammy Garden Ltd v HMRC [2025] UKFTT 274 (TC) (28 February) the FTT found in HMRC’s favour that VAT should have been accounted for from the effective date of registration rather than receipt of the VAT registration number.

A landscape gardener had operated as a sole trader but incorporated Sammy Garden Limited (SGL) on 9 March 2021. On 20 May 2021 a VAT1 form was submitted to HMRC to register SGL for VAT. The date entered for the effective date of registration was 9 March 2021.

It took HMRC two months to process the VAT1 form and notify SGL of its VAT registration number confirming the effective start date of 9 March. This meant that the taxpayer was required to account for VAT on all supplies made after that date. He had however only been...

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