Transpase Ltd v Revenue and Customs (VAT - ZERO-RATING : Exports) [2017] UKFTT 63 (TC) (08 February 2018)

Transpase Ltd v Revenue and Customs (VAT - ZERO-RATING : Exports) [2017] UKFTT 63 (TC) (08 February 2018)

Transpase failed to provide sufficient evidence to satisfy the requirements of paragraph 6.5 of VAT Notice 703, specifically regarding the export destination and the mode of transport and route of export movement. The available documents could not be reconciled to establish these facts, and there was no customer evidence. Therefore, Transpase was not entitled to zero-rate the supplies, and HMRC's assessment was correct.

Citation
[2017] UKFTT 63
Parties
Appellant: Transpase Limited; Respondents: The Commissioners for Her Majesty’s Revenue & Customs
Jurisdiction
United Kingdom
Judgment Date
08 February 2018
Procedural Posture
VAT Zero Rating Appeal / First Tier Tribunal (tax Chamber) Decision
Outcome
Appeal dismissed
Legal Topics
VAT, Zero Rating, Exports, Evidence Requirements
Tax Law VAT Zero Rating Exports Evidence Requirements

Case Brief

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Parties

Transpase Limited

Appellant

The Commissioners for Her Majesty’s Revenue & Customs

Respondents

Procedural Posture

VAT Zero Rating Appeal / First Tier Tribunal (tax Chamber) Decision

Legal Issues

  1. 1 Whether Transpase provided sufficient evidence of export to qualify for VAT zero-rating under section 30(6) VATA 1994 and VAT Notice 703

Ratio Decidendi

Transpase failed to provide sufficient evidence to satisfy the requirements of paragraph 6.5 of VAT Notice 703, specifically regarding the export destination and the mode of transport and route of export movement. The available documents could not be reconciled to establish these facts, and there was no customer evidence. Therefore, Transpase was not entitled to zero-rate the supplies, and HMRC's assessment was correct.

Court Disposition

Appeal dismissed