Maxxim Residential Design Ltd v HMRC

In Maxxim Residential Design Ltd v HMRC [2023] UKFTT 474 (TC) (2 June 2023) the FTT ruled that certain assessments raised by HMRC were out of time but the penalties raised by HMRC were upheld in full despite the time limitations for the assessments.  

The taxpayer was an architectural firm incorporated and VAT registered since 2008. It submitted repayment returns for the period March 2013 to June 2014 inclusive. The repayment return for the period June 2014 was selected for additional checks by HMRC which ultimately led to a wider review of all the repayment returns submitted.  

During the review HMRC found evidence of false invoices used to support input tax claims in the period June 2014 and had reason to believe the practice of falsifying invoices began in March 2013. HMRC raised assessments against the taxpayer under FA 2007 Sch 24 for the periods March 2013 to...