Rizwan Butt v The Commissioners for HMRC

Rizwan Butt v The Commissioners for HMRC

Mr Butt, as director of Quantum, had blind-eye knowledge or at least the means of knowledge that the transactions were connected with fraudulent evasion of VAT, given the extensive education, repeated warnings, and superficial due diligence. The penalties under sections 69C and 69D VAT Act 1994 were properly imposed and calculated. The appeal is dismissed.

Parties
Appellant: Rizwan Butt; Respondents: The Commissioners for His Majesty’s Revenue and Customs
Jurisdiction
England and Wales
Judgment Date
23 April 2026
Procedural Posture
Tax Appeal / Judgment After Full Hearing
Outcome
Appeal dismissed
Legal Topics
Value Added Tax, Input Tax Denial, Missing Trader Intra Community Fraud, Director Penalties, Kittel Principle
Tax Law Administrative Law Value Added Tax Input Tax Denial Missing Trader Intra Community Fraud Director Penalties Kittel Principle

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Parties

Rizwan Butt

Appellant

The Commissioners for His Majesty’s Revenue and Customs

Respondents

Procedural Posture

Tax Appeal / Judgment After Full Hearing

Legal Issues

  1. 1 Whether the appellant knew or should have known that transactions were connected with fraudulent evasion of VAT
  2. 2 Whether penalties under section 69C and 69D VAT Act 1994 were properly imposed on the director

Ratio Decidendi

Mr Butt, as director of Quantum, had blind-eye knowledge or at least the means of knowledge that the transactions were connected with fraudulent evasion of VAT, given the extensive education, repeated warnings, and superficial due diligence. The penalties under sections 69C and 69D VAT Act 1994 were properly imposed and calculated. The appeal is dismissed.

Court Disposition

Appeal dismissed

Orders

  • Penalties under section 69C and 69D VAT Act 1994 against Mr Butt upheld
  • No relief granted to the appellant