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Impact Contracting Solutions Ltd v HMRC

HMRC’s power to deregister where VAT fraud

In Impact Contracting Solutions Ltd v HMRC [2025] EWCA Civ 623 (16 May) the Court of Appeal (CA) upheld the Upper Tribunal (UT) decision that HMRC have the power to deregister a taxable person for reasons related to tax fraud even if the taxpayer makes other legitimate taxable supplies provided that the deregistration is a proportionate step in the circumstances.

This is an important case that looks at the scope of HMRC’s ability to deregister a taxpayer when a VAT registration is being used solely or principally to facilitate fraud if they knew or had the means of knowing of such fraud under the Ablessio principle.

The appellant Impact Contracting Solutions Ltd (ICS) contracted with mini-umbrella companies for the supply of labour and supplied that labour onto its customers that were temporary work agencies. HMRC considered the arrangement...

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