Two wins for HMRC in DCM Optical Holdings narrow the scope of VAT challenges

In DCM (Optical Holdings) Ltd, the Supreme Court has given further guidance on the application of the one-year limit for HMRC to raise a VAT assessment after receiving sufficient evidence of facts. The judgment also confirms that HMRC has an implicit power to refuse to pay a VAT credit while it verifies the validity of the claim and that any unfairness between the position for a repayment trader and an under-declaring payment trader does not amount to unjustified discrimination.