The appellant, Ingliston Driving Experiences Ltd had appealed against an HMRC assessment to VAT of £31,794.30, and a denial of credit for input VAT of £15,200.67, later reduced to £13,109.20 due to inaccuracy.

The assessments related to the VAT period 10/20 covering the period from 1 August 2020 to 31 October 2020.

The VAT assessment and the denial of input VAT both resulted from HMRC’s decision, outlined in a review conclusion letter dated 11 November 2021, to treat Ingliston's supplies as standard rated for VAT purposes, rather than benefiting from reduced rating of 5% during the covid pandemic.

Ingliston Driving Experiences offers a range of supercar driving experiences to members of the public, held at three different circuits in Scotland and Northern Ireland. It is based at Ingliston Circuit on the outskirts of Edinburgh, and runs five to six event days a month.