Zero-rating claim for goods exported to Ireland

The taxpayer which was based in Northern Ireland made supplies of limestone which was processed to be used on new build properties. A dispute arose as to whether supplies of stone for a particular contract qualified for zero rating on the basis that the goods were sold to a VAT-registered business in Ireland and exported to that country.

The taxpayer said he had checked the validity of the VAT number provided by the Irish customer in April 2014 on the Europa website. He had no reason to doubt the customer was not genuine. However in April 2014 the Irish tax authorities cancelled the VAT registration with retrospective effect from August 2013. HMRC accepted zero rating for two of the 11 sales invoices raised over an 18-month period in 2014 and 2015. But the officer said the taxpayer should have checked the VAT number was valid after...