Hall v Revenue and Customs (VAT - Compulsory registration - Alignment of income tax self-assessment and VAT - Validity of closure notice - Whether the Appellant should have been registered for VAT) [2025] UKFTT 1446 (TC) (28 November 2025)

Hall v Revenue and Customs (VAT - Compulsory registration - Alignment of income tax self-assessment and VAT - Validity of closure notice - Whether the Appellant should have been registered for VAT) [2025] UKFTT 1446 (TC) (28 November 2025)

The Tribunal found that HMRC's letter of 21 August 2023 constituted a closure notice for the income tax enquiry, which was therefore closed without adjustment. As the law and HMRC guidance require alignment between income tax and VAT treatment, and the income tax enquiry was closed with no adjustment, the decision to register Mr Hall for VAT was incorrect.

Citation
[2025] UKFTT 1446 (TC)
Parties
Appellant: Steven Hall; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
28 November 2025
Procedural Posture
VAT Registration Appeal / First Tier Tribunal Decision
Outcome
Appeal allowed
Legal Topics
VAT Registration, Income Tax Self Assessment, Closure Notice, Alignment of Tax and VAT Treatment
Tax Law VAT Registration Income Tax Self Assessment Closure Notice Alignment of Tax and VAT Treatment

Case Brief

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Parties

Steven Hall

Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

VAT Registration Appeal / First Tier Tribunal Decision

Legal Issues

  1. 1 Whether HMRC correctly determined that Mr Hall should have been registered for VAT for the period 1 December 2011 to 25 August 2022
  2. 2 Whether HMRC were correct to determine that the self-employed stylist's income should be included in Mr Hall's turnover for VAT purposes

Ratio Decidendi

The Tribunal found that HMRC's letter of 21 August 2023 constituted a closure notice for the income tax enquiry, which was therefore closed without adjustment. As the law and HMRC guidance require alignment between income tax and VAT treatment, and the income tax enquiry was closed with no adjustment, the decision to register Mr Hall for VAT was incorrect.

Court Disposition

Appeal allowed

Orders

  • HMRC's decision to register Mr Hall for VAT for the period 1 December 2011 to 25 August 2022 is set aside.