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The VAT review for June 2025

This month’s review by Joao Martinho and Gary Barnett (Simmons & Simmons) covers the Court of Appeal decision in Impact Contracting Solutions and two recent cases on the meaning of consideration.

Cancelling a VAT registration and abuse of law

In Impact Contracting Solutions Ltd v HMRC [2025] EWCA Civ 623 the Court of Appeal confirmed that HMRC does have the power to cancel a trader’s VAT registration under the Halifax abuse of law principle even where the trader is not themselves acting fraudulently subject to a requirement that such action is proportionate. The court also held that the fact that the trader might also make genuine untainted taxable supplies does not prevent deregistration in principle....

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