Ross Birkbeck has successfully represented HMRC in the Upper Tribunal. Nottingham Forest FC v HMRC [2024] UKUT 00145 (TCC) concerned the one year time limit for VAT assessments in section 73(6)(b) of the VAT Act 1994. The case confirms that the burden of proof when showing when HMRC had all the knowledge of the evidence necessary to assess a taxpayer to VAT rests with the taxpayer.
The Judgement can be found here: