DEFINITION OF CLAIM CLARIFIED IN VODAFONE, BRATT

摘要

The two upper Tribunal decisions in Vodafone (UKUT00B9) and Bratt Auto Services and Bratt Auto Contracts (UKUT0090) cast a similar, interesting light on the concept of a 'claim' of VAT. Bratt provides the less controversial outcome (perhaps) in deciding two points in favour of HMRC. The first in the case of Vodafone was that a claim made for an indeterminate sum, but based on a principle, and a promise of figures later (implicitly, after the deadline for a valid claim), was not a 'claim'. That is unsurprising and follows the First Tier Tribunal's (FTT) decision.