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Conditions not satisfied

24 April 2018
Issue: 4644 / Categories: Tax cases

Transpase Ltd (TC6328)

Evidence of export

The company supplied beauty products clothes and clothing accessories to individuals in Nigeria who mainly ordered them online. The dispute concerned whether the documents produced by the sole company director and shareholder Mr A met the export evidence requirements of VAT Notice 703: Export of Goods from the UK para 6.5 and VATA 1994 s 30(6). This provision confirms that HMRC must be satisfied that ‘the person supplying the goods has exported them to a place outside the member states’. HMRC did not consider this was the case and raised an assessment for underdeclared output tax for the periods March 2012 to June 2015.

The First-tier Tribunal noted that there are seven conditions in para 6.5 all of which have to be met to achieve zero rating. Evidence must be produced that shows:

  • the supplier;
  • the consignor...

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