Silverdoor Ltd v Revenue & Customs (application for amendment of grounds of appeal) [2020] UKFTT 514 (TC) (31 December 2020)

Silverdoor Ltd v Revenue & Customs (application for amendment of grounds of appeal) [2020] UKFTT 514 (TC) (31 December 2020)

The Tribunal allowed Silverdoor's application to amend its grounds of appeal, finding no prejudice to either party or the trial date. The Tribunal issued detailed case management directions to ensure both parties clarify their factual and legal positions before the substantive hearing.

Citation
[2020] UKFTT 514 (TC)
Parties
Appellant: Silverdoor Limited; Respondents: The Commissioners for Her Majesty’s Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
31 December 2020
Procedural Posture
Tax Appeal (first Tier Tribunal) / Application for Amendment of Grounds of Appeal; Case Management Directions
Outcome
Application to amend grounds of appeal allowed; case management directions issued.
Legal Topics
Amendment of Grounds of Appeal, VAT Exemption for Card Handling Services, Penalties for Carelessness, Case Management Directions

Case Brief

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Parties

Silverdoor Limited

Appellant

The Commissioners for Her Majesty’s Revenue and Customs

Respondents

Procedural Posture

Tax Appeal (first Tier Tribunal) / Application for Amendment of Grounds of Appeal; Case Management Directions

  1. 1 Whether Silverdoor may amend its grounds of appeal to clarify its position on card handling services and VAT exemption
  2. 2 Whether the amendment prejudices the Respondents or the trial date
  3. 3 Whether further detail is required in pleadings regarding penalties and factual clarifications

Ratio Decidendi

The Tribunal allowed Silverdoor's application to amend its grounds of appeal, finding no prejudice to either party or the trial date. The Tribunal issued detailed case management directions to ensure both parties clarify their factual and legal positions before the substantive hearing.

Court Disposition

Application to amend grounds of appeal allowed; case management directions issued.

Orders

  • Appellant to amend grounds of appeal by 19 January 2021 to set out relied facts and legal basis for VAT exemption.
  • HMRC may file amended Statement of Case within 28 days of compliance with Direction 1.