A Trees v HMRC

In A Trees v HMRC [2023] UKFTT 339 (TC) (24 March 2023) the FTT ruled that HMRC could strike out parts of the appellant’s grounds of appeal as an abuse of process on the basis that the matters had already been decided in an earlier decision. 

The appellant Mr Trees  was the sole director and beneficial owner of CCA Distribution Ltd (CCA). In 2007 HMRC issued decisions which denied CCA the right to deduct input tax of £9 874 254.54 on the basis that the related transactions related to the fraudulent evasion of VAT and that Mr Trees knew or should have known of that connection. CCA appealed to the FTT which found in HMRC’s favour. 

Following the FTT decision HMRC issued CCA with a civil evasion penalty of £1 974 850 under VATA s 60(1) and on the same day issued Mr Trees...