Nottingham Forest Football Club Limited refuted an assessment of £345,561 in VAT payments, which HMRC issued for the period 08/15 on 29 April 2019.

In its appeal, the club questioned whether the assessment had been made within one year after the evidence of the facts, which HMRC used in justifying the assessment.

This was issued on the basis that the assessment was potentially time-barred under section 73 of the Value Added Tax Act 1994 (VATA), which states that an assessment must be justified ‘one year after evidence of the facts’.

HMRC argued that its knowledge of the facts was completed on 9 May 2018. However, the club believed that it had the necessary knowledge by 20 April 2018.