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Laurence Harris

Laurence Harris Successfully Represents HMRC in £900,000 Kittel Appeal

03/07/2025

Laurence Harris appeared unled in a 7-day First-tier Tribunal (Tax) appeal against the Commissioners’ decisions to deny the appellant company the right to deduct over £900,000 of input VAT.

HMRC’s case was that the transactions underlying the claims to deduct were connected to an MTIC-style labour market VAT fraud. The Commissioners further argued that many of the invoices provided in support of the claims to deduct did not meet the requirements of Regulation 14 of the VAT Regulations 1995.

The director of the appellant company gave evidence that he had no knowledge of any connection to VAT fraud, nor should he have known such. He was cross-examined on his account over the course of two days.

In a lengthy written decision, the FTT refused the appeal in its entirety. The panel found that the director ‘knew perfectly well’ that the underlying transactions were connected to an orchestrated VAT fraud.

The judgment is available here.

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