Telement Ltd v Revenue & Customs [2010] UKFTT 470 (TC)

FTT-Tax
Telement Ltd v Revenue & Customs
[2010] UKFTT 470 (TC) · 2010-10-06
[43]“A person who has no intention of undertaking an economic activity but pretends to do so in order to make off with the tax he has received on making a supply, either by disappearing or hijacking a taxable person's VAT identity, does not meet the objective criteria which form the basis of those concepts which limit the scope of VAT and the right to deduct (see Halifax § 59 and Kittel § 53). A taxable person who knows or should have known that the transaction which he is undertaking is connected with fraudulent evasion of VAT is to be regarded as a participant and, equally, fails to meet the objective criteria which determine the scope of the right to deduct. ” On the meaning of “should have known” Moses LJ said:
“50. The traders contend that mere failure to take reasonable care should not lead to the conclusion that a trader is a participant in the fraud. In particular, counsel on behalf of Mobilx contends that Floyd J and the Tribunal misconstrue § 51 of Kittel . Whilst traders who take every precaution reasonably required of them to ensure that their transactions are not connected with fraud cannot be deprived of their right to deduct input tax, it is contended that the converse does not follow. It does not follow, they argue, that a trader who does not take every reasonable precaution must be regarded as a participant in fraud. 51. Once it is appreciated how closely Kittel follows the approach the court had taken six months before in Optigen , it is not difficult to understand what it meant when it said that a taxable person “knew or should have known” that by his purchase he was participating in a transaction connected with fraudulent evasion of VAT. In Optigen the Court ruled that despite the fact that another prior or subsequent transaction was vitiated by VAT fraud in the chain of supply, of which the impugned transaction formed part, the objective criteria, which determined the scope of VAT and of the right to deduct, were met. But they limited that principle to circumstances where the taxable person had “no knowledge and no means of knowledge” (§ 55). The Court must have intended Kittel to be a development of the principle in Optigen . Kittel is the obverse of Optigen . The Court must have intended the phrase “knew or should have known” which it employs in §§ 59 and 61 in Kittel to have the same meaning as the phrase “knowing or having any means of knowing” which it used in Optigen (§ 55). 52. If a taxpayer has the means at his disposal of knowing that by his purchase he is participating in a transaction connected with fraudulent evasion of VAT he loses his right to deduct, not as a penalty for negligence, but because the objective criteria for the scope of that right are not met. It profits nothing to contend that, in domestic law, complicity in fraud denotes a more culpable state of mind than carelessness, in the light of the principle in Kittel . A trader who fails to deploy means of knowledge available to him does not satisfy the objective criteria which must be met before his right to deduct arises.”
He concluded:[59]“59. The test in Kittel is simple and should not be over-refined. It embraces not only those who know of the connection but those who “should have known”. Thus it includes those who should have known from the circumstances which surround their transactions that they were connected to fraudulent evasion. If a trader should have known that the only reasonable explanation for the transaction in which he was involved was that it was connected with fraud and if it turns out that the transaction was connected with fraudulent evasion of VAT then he should have known of that fact. He may properly be regarded as a participant for the reasons explained in Kittel .[60]The true principle to be derived from Kittel does not extend to circumstances in which a taxable person should have known that by his purchase it was more likely than not that his transaction was connected with fraudulent evasion. But a trader may be regarded as a participant where he should have known that the only reasonable explanation for the circumstances in which his purchase took place was that it was a transaction connected with such fraudulent evasion. ” 8. In relation to the standard of proof, it used to be said that the more serious the allegation the less likely it is that the event occurred and the stronger (or more cogent) should be the evidence before a court concludes that the allegation is established on the balance of probability. The House of Lords in In re B [2009] AC 11 has clarified this. As Lord Hoffmann (with whom, Lord Rodger and Lord Walker agreed) said:
“There is only one rule of law, namely that the occurrence of the fact in issue must be proved to have been more probable than not. Common sense, not law, requires that in deciding this question, regard should be had, to whatever extent appropriate, to inherent probabilities. If a child alleges sexual abuse by a parent, it is common sense to start with the assumption that most parents do not abuse their children. But this assumption may be swiftly dispelled by other compelling evidence of the relationship between parent and child or parent and other children. It would be absurd to suggest that the tribunal must in all cases assume that serious conduct is unlikely to have occurred. In many cases, the other evidence will show that it was all too likely. If, for example, it is clear that a child was assaulted by one or other of two people, it would make no sense to start one’s reasoning by saying that assaulting children is a serious matter and therefore neither of them is likely to have done so. The fact is that one of them did and the question for the tribunal is simply whether it is more probable that one rather than the other was the perpetrator.”
Lady Hale (with whom Lord Scott, Lord Rodger and Lord Walker agreed) said:
“70…Neither the seriousness of the allegation nor the seriousness of the consequences should make any difference to the standard of proof to be applied in determining the facts. The inherent probabilities are simply something to be taken into account, where relevant, in deciding where the truth lies. 72. As to the seriousness of the allegation, there is no logical or necessary connection between seriousness and probability. Some seriously harmful behaviour, such as murder, is sufficiently rare to be inherently improbable in most circumstances. Even then there are circumstances, such as a body with its throat cut and no weapon to hand, where it is not at all improbable. Other seriously harmful behaviour, such as alcohol or drug abuse, is regrettably all too common and not at all improbable. Nor are serious allegations made in a vacuum. Consider the famous example of the animal seen in Regent’s Park. If it is seen outside the zoo on a stretch of greensward regularly used for walking dogs, then of course it is more likely to be a dog than a lion. If it is seen in the zoo next to the lions’ enclosure when the door is open, then it may well be more likely to be a lion than a dog.” 9. Our understanding is that the dangers of the old formulation were first, that it could be misunderstood to be increasing the civil standard of proof to something above the balance of probability; and secondly, that it was illogical to start with considering the seriousness of the allegation in a vacuum and assume that all serious allegations were unlikely and therefore needed cogent proof. Now one starts with determining the likelihood of the allegation having regard to the surrounding circumstances and not in a vacuum. Having done so the only question is whether the allegation is proved to the balance of probabilities. In other words, the inherent probability itself includes the particular circumstances. Contentions of the parties 10. We have listed in paragraphs 12 and 14 below the factors principally relied on by Mr Baker as showing that the Appellant either knew or ought to have known of the connection of the Transaction with fraud. Where relevant we have included Mr Livingstone’s answers to them and our own views. There was no obvious disagreement between them on the law. 11. In relation to the In re B standard for determining the balance of probabilities we have accepted Mr Stone’s evidence that a trader in mobile phones at the time of the Transaction would have been aware that the danger of fraud was a significant one. It follows that in a transaction contains features that are out of the ordinary the trader is on notice that the likely explanation is that there may be a connection to fraud which needs to be investigated. Mr Baker contended that the issue was not whether the trader knew that other people were being fraudulent but rather whether he actually was being fraudulent. In assessing the inherent probability of that, the appropriate context and circumstances must therefore not merely be the extent to which fraud was known about, but rather the extent to which fraud was actually perpetrated and common-place. We do not accept this since it is illogical to test whether knowledge is proved to the balance of probabilities by taking into account probabilities that were not known about at the time. Actual knowledge 12. The following factors were relied on by Mr Baker as indicating that the Appellant was aware that the Transaction was connected with fraud: (1) The inadequacy of checks and due diligence undertaken by the Appellant. In particular no credit or other commercial checks were carried out on Crotek and the Redhill check was made on 3 April 2006 after the Transaction (and after shipping the phones to France on 1 April 2006, although they were still held to the Appellant’s order in the French warehouse). The use by Crotek of an FCIB account was not questioned by the Appellant as Mr Opacic assumed that it was because Crotek’s suppler was overseas. However, we do not think that FCIB was under any suspicion at the time and the use of an offshore account does not of itself indicate fraud. Nor were any credit references taken up for LPDC. No trader references were given. No Redhill check was made. (2) The inference to be drawn by the seeming fabrication of evidence. Mr Baker relies on the dating of Crotek’s trade credit application form on “1-11-06” as suggesting that Mr Opacic completed the document later than the transaction and dated it without thinking. The fact that the form is the same layout as the one completed by LPDC for the Appellant is suspicious. (3) Lies about Telement’s involvement in the mobile phone market. We have concluded that these were short of being deliberate lies but were probably intended to reduce HMRC’s interest in the Appellant’s business. (4) Inferences from the lack of Insurance. We have found that there was no insurance and that Mr Opacic must have known this, which is commercially stupid, but is it more than this? Mr Baker contends that this indicates that the Appellant knew it was not taking any risk and therefore knew that the Transaction was fraudulent. This might be because Mr Opacic had been told that he would incur no loss, which would indicate that he knew that the Transaction was connected to fraud. On the other hand, assuming that someone was masterminding a fraud in relation to the VAT on the Transaction (£71,487.50) for which he needed to purchase phones worth £433,200 at the Appellant’s selling price (which is within Mr Fletcher’s range of what an authorised distributor would need to pay) we do not understand why the fraudster would not want to insure the phones since their loss would be far greater than the VAT evaded and if lost they could not be used for future fraudulent transactions. It would surely have been in the fraudster’s interest to ensure that AFI (if it was party to the fraud) would help to ensure that the phones were insured not only to protect the fraudster but also to make the Appellant’s transaction look more genuine. We could understand the lack of insurance if the phones did not exist, but we have no evidence which would enable us to make any such finding. We are there unable to come to any firm conclusion about the significance of the lack of insurance but given the Appellant’s experience in the export market we consider that it is suspicious. (5) The relationship with AFI. The fax to AFI of 31 March 2006 stated to be following a telephone conversation including “Agreed rate £tba, Insurance £tba (required) is strange because the Appellant in fact paid the freight rate on AFI’s price list and AFI knew that they could not provide insurance as agent but needed to tell the Appellant who to contact, which as a frequent exporter Mr Opacic must have known. (6) IMEI inspections and the role of A1. There does not seem to have been time for A1’s inspection report it to have taken place between the fax to AFI in Southall requiring it at 1813 hours on Friday 31 March 2006 and the phones being checked in at Dover at 0958 next morning, in order for the Appellant to act on the contents of it. In any case the Appellant was not sent the report, which is dated 31 March 2006, until 5 April 2006. One would have thought that the report was needed in order for the Appellant to be satisfied about what it was buying. It is difficult to see what purpose the report served if the Appellant did not receive it in time to do anything about it. At the time it seems that A1 did not check for stolen phones (or if it did the Appellant did not pay for the service). We consider that the Appellant’s lack of interest in the inspection report is suspicious. We deal with IMEI numbers in paragraph 14 below. (7) Non-commerciality of the transactions. Mr Baker relies on the Appellant making a greater mark-up than others in the chain, that there is no commercial sense in the Transaction in non-UK specification phones which had been imported into the UK, the absence of international pricing differences in Nokia phones, the absence of currency differences at the time, the Transaction not being typical of grey market stock shortages or dumping transactions, long chains, back to back transactions and the timing of the transactions and payments under which the phones were released by the Appellant on 7 April 2006 but Crotek was not paid until 11 April 2006. We would expect the Appellant to make a greater mark-up than others in the chain as it had to finance the VAT. We are not particularly concerned with the phones not being UK specification. We agree that the chain was not a normal grey market one but we must concentrate on what was known by the Appellant. On that basis it might have been suspicious of the price offered by Crotek of £215 which is below what Mr Fletcher said an authorised distributor with the maximum discount would have paid. Mr Opacic used the www.ipt.cc website and could have found the prices being offered at the time. Although Crotek did authorise AFI to release the phones to the Appellant on 31 March 2006 before being paid this can be analysed as parting with possession of the phones while they were still subject to a title retention provision. (8) The deliberate keeping of legitimate trading partners separate from the fraudulent deals. Mr Baker relies on the fact that the trade references given to AFI were Unique Distribution and European Telecom, and those given to Crotek were Unique Distribution and Elite Mobile. He contends that it would have been more normal to give AFI a reference of another freight forwarder, DMS, that they used frequently. He suggested that when doing a transaction that it knew was fraudulent the Appellant did not want to use names of its normal business partners. Mr Opacic said that they always used these companies as references as they were known in the trade and they had dealt with them over a long period. In the light of this we are not prepared to find that the names given as references is indicative of knowledge of fraud. (9) Circumstances of the other fraudulent traders in the chain. Mr Baker relies on the fact that we now know that every party in the chain has been involved in MTIC fraud and therefore “The sheer implausibility of [the Appellant] being the sole ‘innocent’ trader in the chain is so great that the possibility can safely be discounted.”
We are not impressed by arguments of guilt by association. Does not the person masterminding an MTIC fraud need an innocent exporter (we use the expressions exporter and importer for simplicity recognising that this is not correct within the EU) or at least someone who does not ask too many questions? The fraudster is not going to put up the input tax to be paid by the exporter in order to disappear with the same money as importer. We would expect the exporter to be someone who puts up the input tax and can reclaim it so that the loss of tax by the disappearing importer is borne by the state. 13. There may be an innocent explanation for some of the above but it is important to look at them as a whole. Our conclusion is that Mr Opacic is not dishonest but that he was turning a blind eye to the possibility of fraud and he was not acting in a commercial way, for example, in completing the Transaction without receiving the inspection report, not making any enquiries about LPDC, not obtaining more details about Crotek and in particular not obtaining HMRC’s confirmation about Crotek’s VAT registration until 5 April 2006, and not insuring the phones. We would categorise this as “blind eye” knowledge which is higher than the test for ought to have known (see HMRC v Olympia [2009] STC 643 at [122]) and amounts to constructive knowledge (at [86]). We would infer that by not taking reasonable precautions the Appellant had actual knowledge of the connection with fraud, but even if this is wrong we shall find below that the Appellant ought to have known of the connection with fraud. Ought to have known 14. In support of his contention that the Appellant ought to have known of the connection with fraud Mr Baker relies on the following: (1) The circumstances of the transaction (as above). (2) Failing to make any further enquiries: (a) Enquiries of Crotek, LPDC, AFI and A1, would be likely to have thrown up questions. For example, further checks on Crotek would have revealed that it was not trading at its last accounting date of 31 July 2005 (see (f) below). (b) Failing to follow up A1’s statement that they had checked for IMEI numbers against “your database.” We do not accept this. All a trader can do is to check that it has not traded in the phones before for which there will be a first time. The possibility of checking these against another database of earlier deals done by the Appellant was not explored. (c) Not obtaining and checking the IMEI numbers which might have indicated that the phones did not exist or that they included stolen ones. We are not sure what checks the Appellant could have done, particularly within the time scale of the Transaction. HMRC could, we assume, have checked them against their NEMESIS database but not in the time scale of the Transaction and we not think that they would have done this at the Appellant’s request. The Appellant might have been able to check the IMEI numbers for stolen phones but how this could be done was not explored. We do not therefore rely on this. (d) Crotek’s using an offshore bank account should have led to further enquiries. (e) If the Appellant was told that Crotek was using an offshore bank account because its supplier was abroad the Appellant should have investigated this. We are not sure what investigations the Appellant could have made. (f) Crotek’s credit limit should have raised questions. Even though the Appellant was not giving any credit to Crotek its supplier must have been. If the Experian Limited report had been obtained at the time of the Transaction it would not have been more favourable that the one at 8 August 2006 which showed that it was not trading at 31 July 2005. We have not accepted that Creditsafe would have given a credit limit of £5,000 but even if it had, a sale of phones to the Appellant for £408,500 plus VAT 9 months later, for which its supplier must have been giving it credit of its purchase price would be slightly less than this amount would raise questions. 15. As with the issue of actual knowledge, some of these may have an innocent explanation but it is important to look at them as a whole. What is clear is that the Appellant could have found out that Crotek had started to trade in mobile phones after 31 July 2005 and in the absence of any accounts since then its financial position would have been unknown. The amended VAT registration with an effective date of 8 September 2005 suggests that it started to trade in electronic goods then, which is less than 7 months before the Transaction. The Appellant did not wait for the Redhill check on its VAT registration. The sale was to LPDC about which virtually nothing was known. The Appellant did not wait for the inspection report before shipping the phones to France. We ask ourselves is this a commercial transaction or is it a transaction in which “he should have known that the only reasonable explanation for the circumstances in which his purchase took place was that it was a transaction connected with such fraudulent evasion.” We consider that it is the latter. There are far too many odd features of the Transaction for any other conclusion to be possible. 16. Accordingly we dismiss the appeal. In their statement of case HMRC warned that they would ask for costs if they won and accordingly we direct, pursuant to the paragraph 7(3) of Schedule 3 to the Transfer of Tribunal Functions and Revenue and Customs Appeals Order 2009, that the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009 do not apply in respect of costs and that the former VAT Tribunals Rules 1986 apply, and that the Appellant pay HMRC’s costs of and incidental to the appeal to be determined in default of agreement on the standard basis by a tax judge. 17. This document contains full findings of fact and reasons for the decision. Any party dissatisfied with this decision has a right to apply for permission to appeal against it pursuant to Rule 39 of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009. The application must be received by this Tribunal not later than 56 days after this decision is sent to that party. The parties are referred to “Guidance to accompany a Decision from the First-tier Tribunal (Tax Chamber)” which accompanies and forms part of this decision notice. JOHN F AVERY JONES TRIBUNAL JUDGE RELEASE DATE: 6 October 2010

Cited in 2 later judgments