VAT assessments raised outside the statutory time limit

In July 2014 the taxpayer submitted a repayment return for the period ended 6/14. HMRC reviewed the return before making the repayment. The officer cross-checked two purchase invoices received from different suppliers back to the suppliers where input tax of £2961.67 and £2 765 had been claimed. He discovered that both the narrative and amounts on the invoices had been changed by the director and that the suppliers had charged VAT of only £50 and £80 respectively on the two invoices. The officer obtained this information on 4 August 2014.

After several cancelled meetings and a failure to contact the sole director and shareholder HMRC declared the taxpayer as a missing trader and cancelled its VAT registration on 25 October 2015.

On 28 October 2015 the officer issued an assessment to cancel all input tax claimed on returns for periods March 2013 to June 2014. This was...