EMJ Telecommunications Ltd v Revenue & Customs [2014] UKFTT 354 (TC) (16 April 2014)

EMJ Telecommunications Ltd v Revenue & Customs [2014] UKFTT 354 (TC) (16 April 2014)

Deduction of input tax is denied because EMJ knew or, at minimum, should have known that its purchases were connected with fraudulent evasion of VAT, based on objective evidence including trading patterns, mark-ups, circularity of funds, and prior warnings.

Citation
[2014] UKFTT 354 (TC)
Parties
Appellant: EMJ Telecommunications Limited; Respondents: The Commissioners for Her Majesty’s Revenue & Customs
Jurisdiction
United Kingdom
Judgment Date
16 April 2014
Procedural Posture
VAT Input Tax Appeal / Final Judgment
Outcome
Appeal dismissed
Legal Topics
VAT Fraud, MTIC Fraud, Input Tax Deduction, Knowledge of Fraud, Contra Trading

Case Brief

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Parties

EMJ Telecommunications Limited

Appellant

The Commissioners for Her Majesty’s Revenue & Customs

Respondents

Procedural Posture

VAT Input Tax Appeal / Final Judgment

  1. 1 Whether EMJ Telecommunications Ltd knew or should have known its purchases were connected with fraudulent evasion of VAT
  2. 2 Whether deduction of input tax should be denied under the Kittel principle

Ratio Decidendi

Deduction of input tax is denied because EMJ knew or, at minimum, should have known that its purchases were connected with fraudulent evasion of VAT, based on objective evidence including trading patterns, mark-ups, circularity of funds, and prior warnings.

Court Disposition

Appeal dismissed

Orders

  • Deduction of input VAT in the sum of £1,036,297.50 is denied to EMJ Telecommunications Ltd.
  • No entitlement to repayment of VAT for periods 05/06 and 06/06.