Endeavour Strategic Developments LLP v Revenue & Customs (VAT - denial of input tax) [2021] UKFTT 93 (TC) (07 April 2021)

Endeavour Strategic Developments LLP v Revenue & Customs (VAT - denial of input tax) [2021] UKFTT 93 (TC) (07 April 2021)

The appeal was dismissed because the Appellant failed to provide sufficient evidence linking input tax to taxable supplies, many invoices related to other entities, and HMRC's assessments were made on the basis of best judgment. The Tribunal found no evidence of bad faith or unreasonableness by HMRC, and the Appellant did not demonstrate entitlement to the input tax claimed.

Citation
[2021] UKFTT 93 (TC)
Parties
Appellant: Endeavour Strategic Developments LLP; Respondents: The Commissioners for Her Majesty’s Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
07 April 2021
Procedural Posture
VAT Appeal / Final Judgment
Outcome
Appeal dismissed
Legal Topics
VAT, Input Tax, Best Judgment Assessment, Evidence, Partial Exemption
Tax Law VAT Input Tax Best Judgment Assessment Evidence Partial Exemption

Case Brief

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Parties

Endeavour Strategic Developments LLP

Appellant

The Commissioners for Her Majesty’s Revenue and Customs

Respondents

Procedural Posture

VAT Appeal / Final Judgment

Legal Issues

  1. 1 Whether HMRC's denial of input VAT was made on the basis of best judgment
  2. 2 Whether the Appellant provided sufficient evidence to support input tax claims
  3. 3 Whether HMRC acted in bad faith or unreasonably in making the assessments

Ratio Decidendi

The appeal was dismissed because the Appellant failed to provide sufficient evidence linking input tax to taxable supplies, many invoices related to other entities, and HMRC's assessments were made on the basis of best judgment. The Tribunal found no evidence of bad faith or unreasonableness by HMRC, and the Appellant did not demonstrate entitlement to the input tax claimed.

Court Disposition

Appeal dismissed

Orders

  • VAT input tax claims denied for periods 01/14 to 10/15 and 04/16 to 10/16
  • No substituted estimate of VAT allowed