Everyday Wholesale Limited appealed against an HMRC decision dated 3 April 2017, which refused a claim for input VAT for £236,896.43 for accounting periods from 2013 to 2016.

HMRC rejected the submission, arguing that the input tax claim was linked to fraudulent evasion of VAT, and that Everyday Wholesale either knew or should have known this.

Originally the company, which was set up in January 2011, operated as Trade Release Ltd and was registered for VAT. It described its activities as ‘business consultancy’ and ‘general wholesale’. The estimated value of turnover in the next 12 months was £100,000.

Since the VAT registration, the appellant company changed its principal place of business on four occasions, all within London.