"Where a request seeks particulars of matters relied upon in support of an allegation of knowledge (actual or constructive), the claimant is requested to set out all matters so relied upon with the utmost particularity so that (for instance) where a particular communication is relied on, it is identified by author, recipient, date. The defendant may apply for an order striking out any allegation of knowledge which is insufficiently particularised."
“… mean that exhaustive and hugely detailed requests for further information are necessarily justified or proportionate.” 19. Mr Jones contends that these cases are illustrations of principle rather than authorities and do not transcend Three Rivers but must be considered in their factual context and therefore they do not provide much, if any, assistance in the present case. However, I agree with and adopt the observations of Judge Mosedale in Ronald Hull Junior Limited v HMRC[2016] UKFTT 525 (TC) where she said: “28. I think this can all be summarised down to this. Fraud must be clearly pleaded; and a claimant must plead the primary facts relied on; where fraud is pleaded, those primary facts must be pleaded in sufficient detail to understand what inferences the court will be asked to draw (see §14). There is no authority that the appellant is entitled to exhaustive or full particulars of the facts relied on. Primary facts must be pleaded; not all the facts. The appellant is also wrong to say that primary facts must be pleaded in full. What are primary facts? 29. That is all very well but what are primary facts? The citations from Three Rivers, Gamatronic and Sunico at §§13, 24 and 27 above recognised that in cases of alleged fraud the court or tribunal is normally asked by the claimant to infer dishonesty from facts which are not themselves direct evidence of fraud. The facts relied on for these inferences are the primary facts and they must be pleaded. 30. The appellant considered that all the facts from which the tribunal will be asked to draw inferences must be pleaded but that has the problem identified of effectively requiring entire witness statements to be pleaded. That would tend to obfuscate rather than clarify the main issues. It seems to me that the judges in the authorities cited above were using ‘primary’ in the sense of ‘main’ or ‘principle’. They were not requiring every detail to be pleaded. Any other conclusion would lead to all the problems outlined in my comments in Citibank cited above at §20. So the primary facts which the party relies on to prove the alleged dishonesty must be pleaded, but not all the details surrounding those primary facts.” 20. It is therefore necessary, with this in mind, to consider the particular requests for further and better particulars in relation to the Consolidated Statement of Case. Consolidated Statement of Case 21. The Consolidated Statement of Case consists of some 37 pages and contains 149 paragraphs. As is usual in cases in which input tax is denied on the basis that an appellant knew or should have known that its transactions were connected to the fraudulent evasion of VAT details of the transactions, “deal chains”, setting out the parties to the transactions, description of the goods, invoice date and number and amounts paid are appended to the Consolidated Statement of Case. 22. After setting out the decisions of HMRC against which Elbrook has appealed (ie the VAT appeals) and summarising its grounds of appeal under the heading “The Appellant’s knowledge of (I) VAT Fraud in its Trade Sector, and (II) that Previous of its Transactions had been traced to Fraudulent Tax Losses” the Consolidated Statement of Case sets out, with examples, how Elbrook’s attention had been drawn to the risks of VAT fraud in relation to its business. 23. Paragraph 34 of the Consolidated Statement of Case provides: “The Respondents’ case against the Appellant is set out below: i. The Appellant’s transaction formed part of an orchestrated scheme to defraud the Revenue. The relevant transaction chains had been orchestrated for the purpose of the fraudulent evasion of VAT. The Appellant’s suppliers, the other “buffer traders”, as well as the fraudulent defaulting traders were knowing participants in the scheme. The Appellant had actual knowledge that its transactions were connected with the fraudulent evasion of VAT. The Respondents’ do no point ton one piece of evidence as establishing that the Appellant was a knowing participant but instead rely upon the cumulative circumstantial evidence for the inference that it was, and ii. In the alternative, the Appellant should have known that its transactions were connected with the fraudulent evasion of VAT by another taxable person, because the relevant transactions permitted no other reasonable explanation.” 24. A list of defaulting traders is set out at paragraph 36 of the Consolidated Statement of Case. Paragraph 137 of the Consolidated Statement of Case sets out the evidence on which HMRC rely to establish the existence of an overall scheme to defraud the Revenue, with further details of the deal chains being appended to the document. 25. Having carefully considered the Consolidated Statement of Case it does, in my judgement, and contrary to the submissions of Mr Jones, provide Elbrook with a sufficient explanation of HMRC’s positon to enable it to understand the case it has to meet. Request for Further and Better Particulars 26. The first request for further and better particulars states: “Save as set out in paragraphs 138 – 147 of the Consolidated Statement of Case each and every fact or matter relied upon in support of the averment that the Appellant had the alleged actual knowledge. (It is understood that the Respondents aver that they do not point to one piece of evidence, but, instead, upon cumulative circumstantial evidence. In those circumstances, the particulars required are of each and every fact or matter (whether circumstantial or otherwise) which, it is alleged, whether taken alone or cumulatively, gives rise to the inference for which the Respondents contend). If the Respondents do not rely upon any factual matters other than those set out paragraphs 138 – 147, please make that explicit. 27. Request 2 refers to the use of the expression “inter alia” in paragraph 137 of the Consolidated Statement of Case which states that HMRC rely on “inter alia” the “following evidence [listed from i to x] as establishing the existence of an overall scheme to defraud the Revenue of which the Appellant’s transactions formed part” and requests particulars of: “The facts, matters or evidence which has not been set out in paragraph 137 but which is included within the expression “inter alia”” 28. The third request is also in relation to paragraph 137 of the Consolidated Statement of Case and seeks information: “In circumstances where the Respondents have specifically alleged that the Appellant had actual knowledge that its transactions/purchases were connected with the fraudulent evasion of VAT, each and every fact and matter relied upon in support of the assertion that the Appellant was aware of each of the factual matters set out at (i) – (x) in paragraph 137.” 29. The fourth request seeks the percentage proportion of soft drinks that Elbrook purchased from two if its suppliers. Requests five to eight are made in relation to paragraph 146 of the Consolidated Statement of Case which states that Elbrook “consistently purchased goods at a cost lower than it could purchase directly from the manufacturer at a cost [it] could not find elsewhere”