FS Commercial Limited (Appellant) v HM Commissioners for Revenue and Customs (Respondent)
Tuesday 20 January 2026
By Appellant’s Notice filed on 2 April 2025 and issued on 3 April 2025 the Appellant appealed the decision of the Upper Tribunal (Tax Chamber), judgment being delivered on 14 January 2025.
FS Commercial Ltd is appealing a decision by the Upper Tribunal (Tax Chamber) dated 14 January 2025, which upheld HMRC’s assessments under s.73 Value Added Tax Act 1994 for over £19 million (preferred) and £15 million (alternative) due to insufficient evidence of input tax and payment of consideration. The First-tier Tribunal (FTT) ruled that its jurisdiction was supervisory and excluded invoices not provided to HMRC at the time of its decision. The Upper Tribunal agreed, stating the FTT could only consider facts before HMRC’s decision-maker.
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