Scott Joseph Studio Ltd v Revenue and Customs (VAT - INPUT TAX RECLAIM - APPLICATION TO STRIKE OUT IN PART) [2025] UKFTT 1262 (TC) (24 October 2025)

Scott Joseph Studio Ltd v Revenue and Customs (VAT - INPUT TAX RECLAIM - APPLICATION TO STRIKE OUT IN PART) [2025] UKFTT 1262 (TC) (24 October 2025)

The Appellant's claims relating to personal expenditure, zero-rated or exempt purchases, and claims unsupported by VAT invoices or sufficient alternative evidence have no realistic prospect of success. Regulation 111 does not impose a time limit on HMRC's ability to assess. The Tribunal's jurisdiction over HMRC's discretion to accept alternative evidence is supervisory, and the Appellant failed to meet the high bar required to challenge HMRC's refusal.

Citation
[2025] UKFTT 1262
Parties
Appellant: Scott Joseph Studio Limited; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
24 October 2025
Procedural Posture
VAT Input Tax Appeal / Application to Strike Out in Part
Outcome
Application to strike out in part granted
Legal Topics
VAT, Input Tax Reclaim, Strike Out Applications, Tribunal Procedure
Tax Law VAT Input Tax Reclaim Strike Out Applications Tribunal Procedure

Case Brief

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Parties

Scott Joseph Studio Limited

Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

VAT Input Tax Appeal / Application to Strike Out in Part

Legal Issues

  1. 1 Whether parts of the Appellant's VAT input tax appeal should be struck out for having no reasonable prospect of success under Rule 8(3)(c) of the Tribunal Procedure (First-tier Tribunal)(Tax Chamber) Rules 2009

Ratio Decidendi

The Appellant's claims relating to personal expenditure, zero-rated or exempt purchases, and claims unsupported by VAT invoices or sufficient alternative evidence have no realistic prospect of success. Regulation 111 does not impose a time limit on HMRC's ability to assess. The Tribunal's jurisdiction over HMRC's discretion to accept alternative evidence is supervisory, and the Appellant failed to meet the high bar required to challenge HMRC's refusal.

Court Disposition

Application to strike out in part granted

Orders

  • Parts of the Appellant's appeal relating to personal use, zero-rated/exempt purchases, and unsupported claims are struck out.