Silverdoor Ltd v Revenue & Customs (application for amendment of grounds of appeal) [2020] UKFTT 514 (TC) (31 December 2020)
The Tribunal allowed Silverdoor to amend its grounds of appeal as no prejudice was identified, and issued directions for further pleadings and evidence to clarify factual and legal bases for exemption and penalties.
- Citation
- [2020] UKFTT 514
- 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 / Application for Amendment of Grounds of Appeal
- Outcome
- Application to amend grounds of appeal allowed; directions issued for further case management.
- Legal Topics
- VAT Exemption, Penalties, Amendment of Pleadings, Case Management Directions
Case Brief
Summary, issues, holding and outcome
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Parties
Silverdoor Limited
Appellant
The Commissioners for Her Majesty’s Revenue and Customs
Respondents
Procedural Posture
Tax Appeal / Application for Amendment of Grounds of Appeal
Legal Issues
- 1 Whether Silverdoor's card handling services are exempt supplies under Item 1, Group 5, Schedule 9 VATA 1994
- 2 Whether Silverdoor was careless in not accounting for VAT
- 3 Whether amendment to grounds of appeal should be permitted
Ratio Decidendi
The Tribunal allowed Silverdoor to amend its grounds of appeal as no prejudice was identified, and issued directions for further pleadings and evidence to clarify factual and legal bases for exemption and penalties.
Court Disposition
Application to amend grounds of appeal allowed; directions issued for further case management.
Orders
- Appellant to amend grounds of appeal by 19 January 2021 to set out facts and legal basis for exemption.
- HMRC may file amended Statement of Case within 28 days of compliance.
Full Case Text
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