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6 May 2026

Tax law [2026] UKFTT 663 (TC)

Smith v Revenue and Customs (INCOME TAX and VAT)

Smith v Revenue and Customs (INCOME TAX and VAT) [2026] UKFTT 663 (TC) (06 May 2026)

The Tribunal upheld HMRC’s income tax and VAT assessments and most penalties, finding the appellant continued to run the business after March 2003, but ordered recalculation where figures overcharged.

Discovery assessments
Best judgment assessments
Tax penalties
Vat registration and deregistration
Tax residency
Burden of proof

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8 Feb 2022

Tax law [2022] UKFTT 47 (TC)

IMPACT CONTRACTING SOLUTIONS LIMITED v Revenue & Customs (VAT - preliminary issue - whether Ablessio principle only applicable to party committing VAT fraud itself)

IMPACT CONTRACTING SOLUTIONS LIMITED v Revenue & Customs (VAT - preliminary issue - whether Ablessio principle only applicable to party committing VAT fraud itself) [2022] UKFTT 47 (TC) (08 February 2022)

The Tribunal held that Ablessio can apply to a taxpayer that facilitates another party’s VAT fraud, and that knowledge or constructive knowledge is required.

Vat registration and deregistration
Abuse of rights doctrine
Facilitation of vat fraud
Application of ablessio principle
Proportionality in tax enforcement
Vat-registration

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Smith v Revenue and Customs (INCOME TAX and VAT)

IMPACT CONTRACTING SOLUTIONS LIMITED v Revenue & Customs (VAT - preliminary issue - whether Ablessio principle only applicable to party committing VAT fraud itself)