For the first time the Upper Tribunal has considered the impact and scope of the Ablessio abuse principle for deregistering a taxpayer from VAT. Howard Watkinson and Joshua Carey (Devereux Chambers) examine the judgment and its implications.
In Impact Contracting Solutions Ltd v HMRC [2023] UKUT 215 (TCC) the appellant (Impact Contracting Solutions Ltd) operated in the labour supply market. It contracted with mini-umbrella companies (MUCs)for the supply of labour and supplying that labour on to its customers which were temporary work agencies. A question arose as to the nature of the supplies it was both being supplied with and supplying to its customers. HMRC considered that the appellant was registered for VAT principally or solely to abuse the VAT system by facilitating VAT fraud and that it knew or should have known of that facts. Consequently HMRC deregistered the appellant from the VAT system....
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For the first time the Upper Tribunal has considered the impact and scope of the Ablessio abuse principle for deregistering a taxpayer from VAT. Howard Watkinson and Joshua Carey (Devereux Chambers) examine the judgment and its implications.
In Impact Contracting Solutions Ltd v HMRC [2023] UKUT 215 (TCC) the appellant (Impact Contracting Solutions Ltd) operated in the labour supply market. It contracted with mini-umbrella companies (MUCs)for the supply of labour and supplying that labour on to its customers which were temporary work agencies. A question arose as to the nature of the supplies it was both being supplied with and supplying to its customers. HMRC considered that the appellant was registered for VAT principally or solely to abuse the VAT system by facilitating VAT fraud and that it knew or should have known of that facts. Consequently HMRC deregistered the appellant from the VAT system....
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