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Dreyer v Revenue and Customs (VAT - civil evasion penalty of almost £5m for dishonest behaviour) [2025] UKFTT 1336 (TC) (10 November 2025)
The tribunal refused a late VAT penalty appeal, holding that the 30-day time limit remained effective, no review was notified, and delay was unjustified.
Trees v Revenue and Customs (VAT - penalties - director's liability notice) [2024] UKFTT 516 (TC) (06 June 2024)
The tribunal dismissed Ashley Trees’ appeal against a VAT director’s liability notice and rejected his abuse-of-process challenge to HMRC's reliance on dishonesty.
Hanlon v Revenue & Customs (VAT : civil evasion penalty - attribution to director of company) [2024] UKFTT 175 (TC) (27 February 2024)
The First-tier Tribunal held that a company director acted dishonestly in relation to VAT evasion and upheld HMRC’s recovery of the full penalty from him.
Hanlon v Revenue & Customs (VAT : civil evasion penalty - attribution to director of company) [2024] UKFTT 175 (TC) (27 February 2024)
The Tribunal held that a company director’s conduct was dishonest and upheld HMRC’s decision to recover the full VAT civil evasion penalty from him.
Karpavicius & Anor v Revenue and Customs (VAT - sections 60 & 61 VATA - personal liability notices in respect of dishonest evasion penalties - whether penalties properly chargeable to the companies - whether penalties recoverable from appeallants - para. 4 Finance Act 2007, Schedule 24 (Commencement of Transitional Provisions) Order 2008 (SI/2008/568) considered) [2024] UKFTT 1097 (TC) (06 December 2023)
The companies' extended failure to submit VAT returns and pay liabilities, or to rectify insufficient central assessments, constituted dishonest conduct for the purpose of evading VAT under section 60 VATA, judged by objective standards. This dishonesty was attributable to the appellants as directors under section 61 VATA. However, the penalties must be reduced to reflect appropriate mitigation for cooperation and disclosure, and certain periods and amounts were excluded or adjusted based on the facts and error corrections. The transitional provisions validly preserved the application of sect…
Source excerpt
Karpavicius & Anor v Revenue and Customs (VAT - sections 60 & 61 VATA - personal liability notices in respect of dishonest evasion penalties - whether penalties properly chargeable to the companies - whether penalties recoverable from appeallants - para. 4 Finance Act 2007, Schedule 24 (Commencement of Transitional Provisions) Order 2008 (SI/2008/568) considered) [2024] UKFTT 1097 (TC) (06 December 2023)
The extended period of deliberate omission to file VAT returns and pay liabilities constituted dishonest conduct for the purpose of evading VAT under section 60 VATA. This dishonesty was attributable to the appellants as directors. Penalties are recoverable from them under section 61 VATA, but the appropriate mitigation for cooperation and disclosure is 65%, resulting in reduced penalty amounts.
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EVERYDAY WHOLESALE LIMITED v Revenue & Customs (VALUE ADDED TAX - input tax deductibility - right to deduct restricted under principles in Kittel) [2023] UKFTT 78 (TC) (20 December 2022)
VAT appeal over alcohol purchases dismissed after the tribunal found the appellant’s transactions were connected to fraudulent evasion and that it knew or should have known.
Byers v Revenue & Customs (VALUE ADDED TAX : penalty for under-declaration) [2019] UKFTT 310 (TC) (13 May 2019)
The Tribunal dismissed Mr Byers’ appeal against a VAT civil evasion penalty, finding the under-declared VAT was attributable to his dishonesty and rejecting an Article 6 delay challenge.
Byers v Revenue & Customs (VALUE ADDED TAX : penalty for under-declaration) [2019] UKFTT 310 (TC) (13 May 2019)
The tribunal upheld a VAT civil evasion penalty against Karl Byers, finding the under-declaration was attributable to his dishonesty and dismissing Article 6 delay arguments.
Morgan Drinks Ltd & Anor v Revenue & Customs (PROCEDURE - MTIC - ALCOHOL WHOLESALERS APPROVAL SCHEME) [2018] UKFTT 386 (TC) (22 June 2018)
The tribunal dismissed an application to consolidate a new MTIC tax appeal with earlier Alcohol Wholesalers Approval Scheme appeals.
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