Christopher Swales v Revenue & Customs (VAT - BUILDERS : Do -it-yourself) [2019] UKFTT 277 (TC)

FTT-Tax
Christopher Swales v Revenue & Customs (VAT - BUILDERS : Do -it-yourself)
[2019] UKFTT 277 (TC) · 2019-02-11
[14]“14. It is apparent from the letters written by HMRC officers, when communicating to the appellant the original decision to refuse to meet the claim and on statutory review of that decision, that although Note (2) was reproduced in full, reliance was placed entirely on paragraph (c). No reference was made to any other provision of the Notes, or to s 35 itself. The question before us, nevertheless, is not simply whether Note (2)(c) is engaged, but whether the provisions of s 35, interpreted in accordance with the relevant Notes, apply to the work. Because the work actually undertaken and the plans differ, we need also to touch on Note (2)(d), and it is convenient to deal with that provision first.[15]That Note imposes two requirements: that planning consent has been obtained; and that it has been complied with. Plainly the first part of the requirement is satisfied; the question is whether the divergence between the approved plans, or at least the second of them, and the finished building offends the second. Quite what is meant by the phrase “in accordance with that consent”, in this context, is unclear. At one extreme it could require HMRC and, on appeal, this tribunal to decide whether the consent has been complied with in every detail. At the other it could mean no more than that the consent allows for development broadly equivalent to that undertaken, rather than for something different such as, for example, the conversion of the existing building into a shop.[16]Some help on the point may be derived from the decision of this tribunal in John and Susan Kear v Revenue and Customs Commissioners [2013] UKFTT 95 (TC) , in which consent was given for the conversion of three adjacent commercial buildings to a live-work unit, one building forming the working part and the other two the living space. The consent was specific about which parts of the resulting building could be used for each purpose, and a number of other matters. The tribunal determined that there were several breaches of the conditions, particularly of those prescribing the use which could be made of each part, to the extent that the district valuer, when assessing the building for council tax purposes, found that the extent of the commercial use of the building was too small to warrant separate assessment; in essence there was little more than nominal commercial use. The tribunal decided that those breaches were sufficient to engage Note (2)(d), and that the work could not benefit from the provisions of s 35.[17]There is no equivalent provision here about the extent of the working or the living area, beyond what is shown on the approved plan, which is itself very imprecise: the “work at home area” is identified by that text, but its boundaries are not demarcated. The conditions in the planning consent limit the use to be made of the working area to Class B1 in the Schedule to the Town and Country Planning (Use Classes) Order 1987, a class which includes general office work of the kind undertaken by the appellant and her husband, but say nothing about the location or the extent of the area to be so used. Thus this case is rather different from Kear .[18]We do not need to decide precisely where in the spectrum we identify in para 15 above the line should be drawn. It is sufficient to say that we have concluded that it is not a necessary requirement that HMRC or the tribunal should be satisfied that any requisite consent has been complied with in every particular. We reach that conclusion from the proposition that it is not the province of HMRC or this tribunal to police the planning rules. Whether the finished building complies with the conditions imposed by the planning authority must be a matter for that authority, and it is not for us to usurp its function. It will be apparent from what has gone before that it is difficult to resist the conclusion that the planning authority in this case has not insisted on strict compliance with the approved plans. But in the absence of any adverse action by it—and there was no evidence of any such action in this case—it is, in our view, proper for the tribunal to proceed on the footing that the work was lawful (as s 35(1)(b) requires) and that there was sufficient compliance with the planning consent to satisfy Note (2)(d). We distinguish this case from Kear on the basis that, there, the disregard of the planning consent was almost complete; here, there has been compliance with the spirit, even if not the strict letter, of the consent. [ Our emphasis ]108. HMRC refer to HMRC v Asim Patel [2014] UKUT 361 (TCC) (“ Patel ”) in the Upper Tribunal. This was a case heard by that Tribunal after Pearson . Judge Bishopp was the presiding judge in the Upper Tribunal and Patel was a case which dealt with Rule 2(d). We are sure that if Judge Bishopp had had any doubt about what he had said in Pearson he would have raised it.109. We follow Pearson not only because any decision of Judge Bishopp, the then President of the Tax Chamber of the First-tier Tribunal, is worthy of great respect even if not binding, but because Judge Thomas, a member of the Pearson Tribunal, has reconsidered the decision to which he was a contributing party and sees no reason to change his mind.110. The evidence from the appellant is that no one in UDC was under the impression that the three walls were to be retained and certainly not that it was a condition of the planning consent that they must be. This was not based on speculation but on his discussions with Mr Theobald of UDC. The appellant’s account of his discussion was of course hearsay, but HMRC were well aware of that fact and what the appellant said about UDC’s attitude and did not seek to challenge it. They relied instead on the fact that Mr Heggie had demanded the appellant produce a letter in writing from UDC, something UDC were not prepared to do. We say more about this misguided approach later.111. This is a classic example of what the Tribunal in Pearson said was not appropriate. The appellant has shown us convincing evidence in the form of Planning Circular 11/95 that the retention of walls where there would otherwise be a demolition to ground level is something that would only appear in a planning approval if it was required in relation to a listed building.112. The shed was not listed and the planning approval contained no condition. But beyond that the plans do not give any indication that the walls were to be retained apart from, arguably, the blue lines. But that is highly arguable: HMRC were putting themselves forward as experts in architectural and planning drawings, again usurping a function that is not rightly theirs. We find the appellant’s explanations of this convincing – he is after all an architect used to planning applications and drawings. We find that the thicker blue lines do not indicate any intention to retain the walls.113. We are also convinced by the appellant’s point that retaining the walls would itself have made the works unlawful under the Building Regulations.114. But we do not need to be convinced by what the appellant says about the plans or the effect retention would have. The walls were not retained, as the photographs make absolutely clear, so Notes 16 and 18 have the effect that in law the shed ceased to be an existing building, even though the slab was retained, and consequently what was done was in tax terms construction of a dwelling, not an extension or enlargement of an existing building (whatever the correct description, if there is a need for one, in planning terms).115. The demolition of the walls was not contrary to the planning consent because there was nothing in the consent and the plans which form part of it that required their retention and forbade their demolition, or even assumed their retention, and applying Pearson we find that there was no action by UDC to suggest otherwise, even after Mr Allanah had seen what was done. And any points HMRC made about the application under and compliance with the Building Regulations were given their quietus by the fact that the appellant got a completion certificate.116. We therefore find that the appellant met the condition in Note 2(d). It follows that the appellant’s claim meeting the requirement of regulation 201(b)(iv) of the VAT Regulations was in time for the purposes of regulation 201(a). Other matters117. It is entirely possible that HMRC will seek to appeal this decision and may obtain leave to do so. We obviously do not give any view of what our reaction would be to such an application, and in any case if we were to refuse leave, HMRC could seek leave from the Upper Tribunal.118. Against that possibility we think it might be helpful if we set out our views on some of the other points that were canvassed by HMRC and which engaged the parties in detailed correspondence and in ADR proceedings.119. The matters we discuss here are the “no separate use or disposal” issue (Note 2(c)) and the “annexe/ancillary” issue. No separate use or disposal120. We recognise that this issue did not feature in Mr Hartley’s review letter or Mr Sanusi’s SoC. But as late as 14 February 2018, five months after the notice of appeal against Mr Hartley’s variation of Mr Heggie’s decision, Mr Heggie was still plugging away at the issue and on 29 March 2018, having refused to accept the appellant’s evidence as good enough for his purposes, seems to have assumed that the issue would feature in the appeal hearing.121. Note 2(c) makes it a condition of a building satisfying the test that it is “designed as a dwelling” that:
“the separate use, or disposal of the dwelling is not prohibited by the term of any covenant, statutory planning consent or similar provision”. 122. In this case as there was a statutory planning consent we do not need to look further than it. 123. Mr Heggie gave the appellant a paragraph (14170) from their VCONST Manual on this topic (see §54). VCONST 14170 is headed: “Dwellings - an explanation of terms: what ‘designed as a dwelling or number of dwellings’ means: how Note 2(c) is expressed in planning notices.” 124. It starts by saying: “You should not expect the wording of Note 2(c) to appear as an explicit condition in the planning permission. Planners tend to adopt a form of wording that meets the particular circumstances of the case and often use the word ‘ancillary’ to tie use or disposal of the permitted dwelling to something else.” 125. What in fact Mr Heggie gave the appellant was the second sentence of the extract in §124 and he did not quote or refer to the heading. Nor did he refer to the remainder of the Manual page. What the next paragraph says is: “The following are examples of how a Note 2(c) prohibition has been expressed in a planning permission:” 126. There follows a list of typical conditions in planning approvals which HMRC constituted prohibitions on separate use or disposal, including one in Planning Circular 11/95 issued by ODPM (as it then was – now DCLG). After that there is a list of cases from before 2010 where Note 2(c) was in issue and the particular prohibition in the planning consent in the case, with the Manual indicating whether the wording used in the planning consent in that case fell within Note 2(c) or not. 127. What Mr Heggie was failing to disclose then was that it was HMRC’s view that the prohibition had to be found in the conditions of the planning consent (a view wholly consistent with the wording of the Note). The appellant had supplied a copy of Circular 11/95 in his SoC. The Circular is headed “The Use of Conditions in Planning Permissions”
. What VCONST 14170 says of it is:
“Planning Permission Circular 11/95, issued by the Office of the Deputy Prime Minister, provides the following model planning condition where the creation of an additional dwelling would be unacceptable for planning purposes: The extension (building) hereby permitted shall not be occupied at any time other than for purposes ancillary to the residential use of the dwelling known as [ ]. This model condition doesn’t meet Note 2(c). Planning Authorities aren’t obliged to follow this model condition and can set their own condition. The Tribunal has examined alternative conditions in the cases below. Where a condition is framed in the same way, the Tribunal’s decision can be followed, except where indicated. If you are in any doubt about whether a covenant, planning consent or similar document meets Note 2(c), you should consult the Construction Unit of Expertise.” 128. On “Granny/Staff Annexes” the Circular says: 98. Some extensions to dwellings are intended for use as 'granny annexes'. It is possible that a 'granny annex' which provides independent living accommodation, could subsequently be let or sold off separately from the main dwelling. Where there are sound planning reasons why the creation of an additional dwelling would be unacceptable it may be appropriate, to impose a planning condition to the effect that the extension permitted shall be used solely as accommodation ancillary to the main dwelling house. See model condition 47. [The one in VCONST 14170] 99. The same is true for separate buildings (often conversions of outbuildings) intended for use as 'granny annexes'. In these cases it is even more likely that a separate unit of accommodation will be created. 129. It is in our view absolutely clear that the Condition in Note 2(c) was met. “Annexe/ancillary” 130. This is the issue which Mr Hartley did not consider in his review, but which he said might come up before the Tribunal. It didn’t because Mr Sanusi agreed it as not in issue, but he had, as we have mentioned, put forward HMRC’s contentions on the point, which he took from Mr Hartley’s letter in which he was drawing the appellant’s attention to points about the issue, and in particular Note 16(c) to Group 5 which says: “(16) For the purpose of this Group, the construction of a building does not include— … (c) subject to Note (17) below, the construction of an annexe to an existing building.”
Note 17 is irrelevant as it applies only where an annexe is intended to be used for charitable purposes. 131. HMRC’s submissions started with a reference to the planning application that refers to a “granny annex ancillary to existing main dwelling”, and to the planning consent which refers to a residential annexe. They argued that the appellant had not provided evidence that the “property” (sc the “annexe”) had a “council tax band” (sc a separate council tax liability from the main house) and that the property had a different address. 132. Nor, they said, had the appellant provided a confirmation from UDC that the property could be sold separately nor evidence from them to confirm what they meant by a “residential annexe” and if they considered that the construction was bound or tied to the existing house in any meaningful way. 133. The appellant refers to VAT Notice 708 3.2.6 on “annexe” although primarily in connection with the “separate use or disposal” argument, as HMRC were saying that because the building was described as an annexe in the planning consent, it must follow that the separate use restriction applied and the condition in Note 2(c) was not met. 134. Despite what HMRC said about the definition in 3.2.6 applying only where Note 17 is in issue, there is no other definition of annexe in the VAT Notice. In this context the appellant referred to Colchester . 135. We are grateful to the appellant for bringing Colchester to our attention as not only is it a binding authority in its own right, it comprehensively discusses another binding authority, Cantrell and another (t/a Foxearth Lodge Nursing Home) v Commissioners of Customs and Excise (No 2) [2003] EWHC 404 (Ch) , [2003] STC 486 (“ Cantrell No 2 ”). Rather than try to summarise the decisions we think we can do no better than set out several paragraphs from Colchester :
“15. In its second decision, the Tribunal found that the new building was an annexe and dismissed the appeal. Mr and Mrs Cantrell appealed again to the High Court. In [ Cantrell No 2 ], Sir Andrew Morritt V-C defined annexe in Note (16) to Group 5 of Schedule 8, at [16] – [17] of the judgment, as follows: ‘The reference to an “annexe” in Note (16) when compared with the references to “enlargement” of or “extension” to the existing building introduces a different concept. Thus they may be physically separate so that the connection between the two is by way of some other association. But the Tribunal seems to have thought that any association is enough. In my view that cannot be right. If there were a sufficient association between building A and building B, on the Tribunal’s conclusion each would be an annexe of the other. So to hold would ignore the plain inferences to be drawn from the use of the word “annexe”.’ An annexe is an adjunct or accessory to something else, such as a document. When used in relation to a building it is referring to a supplementary structure, be it a room, a wing or a separate building. 16. Sir Andrew Morritt observed, at [20] of the judgment, that: ‘The judgment of Lightman J was directed primarily to the conclusion of the Tribunal in their first decision that the Phase I works constituted the enlargement of the New Barn. In that context, and in the context of an extension, I understand and agree that the relevant considerations are those which arise from the comparison of physical features of the existing building before and after the works in question. But in the case of an alleged annexe the requirement that such a construction should be an adjunct or accessory to another may require some wider enquiry. It is unnecessary to reach any concluded view on that question to decide this case.’” 136. Pausing there we would, were we called upon to decide, have no hesitation in saying that Xanadu was not an adjunct or accessory to the main house. We go on with Colchester : “22. … Mr Colchester criticised the FTT for omitting the final sentence of [20] of Cantrell No 2 which says: “It is unnecessary to reach any concluded view on that question to decide this case.” 23. Mr Colchester submitted that the final sentence of [20] of Cantrell No 2 showed that Sir Andrew Morritt adopted and applied Lightman J’s approach. We regard this submission as unsustainable. Reading [20] and [21] of Cantrell No 2 together, it is clear that Sir Andrew Morritt considered that there was no need for a wider enquiry where there was nothing in the physical features of a building to suggest that it was an adjunct or accessory to another and thus an annexe. He did not make a wider enquiry in Cantrell No 2 because he did not need to do so. Sir Andrew Morritt did not rule out the need for a wider enquiry in cases where the position is less clear than it was in Cantrell No 2 but rather accepted that it may be necessary in such cases. Because he did not need to undertake a wider enquiry in Cantrell No 2 , Sir Andrew Morritt’s observations on this point are obiter dicta. Nevertheless, we consider that they indicate an approach in relation to the issue of whether a structure is an annexe which is clearly correct and should be followed where the physical features of a building in themselves do not clearly lead to a conclusion as to whether or not it is an annexe. The status of the new building in this case was not as clear as in Cantrell No 2 . We consider that the FTT adopted the correct approach to determining whether the new building was an annexe of the Cottage when it undertook a wider enquiry, ie considered matters other than the physical characteristics and functionality of the new building only. … 25. Mr Colchester contended that if a wider enquiry were needed, which he did not accept, then the FTT had erred by considering irrelevant factors such as the intended use of the new building as indicated by the Written Justification document. We consider that the FTT in this case properly considered evidence that was relevant to the issue of whether the new building was an adjunct or accessory to the Cottage. In our view, such evidence includes, in addition to the physical characteristics of both structures which may or may not be determinative of the issue, the matters identified by Lightman J in Cantrell No 1 as illuminating the potential for use inherent in the building, namely “the terms of planning permissions, the motives behind undertaking the works and the intended or subsequent actual use”
. Where the physical features do not provide (as they did in Cantrell No 2 but did not do in this case) a clear indication of whether or not a structure is an annexe, it is necessary to conduct a wider enquiry and consider matters such as the planning permission and intended use of the new building in order to determine its status.” 137. In our view there would be no need in this case to make the “wider enquiry” referred to by the Vice-Chancellor in Cantrell No 2 . The gap of over 40 metres is sufficient to show that Xanadu is not an annexe. But were there a wider enquiry it would, we think, simply point in the same direction. The terms of the planning permission did not prohibit separate sale or disposal, and although they did use the term “annexe” we do not agree that this term in the planning permission must be construed by reference to its meaning in Note 16 of Group 8 (see for example paragraphs 98 and 99 of the Planning Circular 11/95 quoted at §128). The motives for the work were to give the appellant and his wife as much independence as possible in a self-contained building designed for them (eg the access ramp) and to get out from under the feet of their son Tristin, while still being available for child minding duties. And that was the actual use. 138. We put little store by VAT Notice 4.2.6. It clearly supports the appellant’s position, but as the Upper Tribunal pointed out in Colchester at [30] it requires an annexe to be actually abutting the main building, which from Cantrell No 2 can be seen not to be a requirement [4] . We do not however accept HMRC’s view that the VAT Notice is only relevant at this point to charities falling within Note 17. The reference in Note 17 to an “annexe” cannot possibly have a different meaning from that in Note 16: what Note 17 is doing is carving out a subset of Note 16 annexes which do qualify for zero-rating. 139. HMRC’s questions in this about council tax and a different address are irrelevant to whether Xanadu was an annex. More relevant is that all utilities were separate. And we observe that the facts in Colchester , where this Tribunal held that the outbuilding was an annexe are a very long way removed from those in this appeal. The building in Colchester was clearly ancillary to and used for the purposes of the household occupying the main house: the opposite is the case here. The penalty letter 140. No assessment to any penalty was before the Tribunal, and from what we have seen none has to date been issued. But one has been threatened, and the time limit for making a penalty assessment under Schedule 24 FA 2007 (the provision mentioned by HMRC) does not expire until 12 months after the date of determination of this appeal. HMRC have not said that they would not raise a penalty assessment after the determination. Even though this decision has gone against HMRC there does not seem to be anything to prevent HMRC issuing a “protective” penalty assessment pending a decision from the Upper Tribunal on any appeal. 141. Obviously what we say below is not necessary for our decision and that decision is in any case not binding authority. But there are aspects of what had been said, and the effect on it on the appellant, about which we think we should comment. 142. The matters which we find disquieting are these: (1) The penalty letter refers to the rejection of the claim in a letter of the same day for the “reason (s)” detailed in that rejection letter. No one who was not an expert in the law relating to s 30 and Group 5 Schedule 8 VATA reading that letter would understand the reason (singular) why it was rejected, but that is a criticism of the rejection letter, not the penalty letter. (2) The letter required a response by return of post. That is quite ridiculous when among other things the letter suggested that the recipient liaise with his “Agent” (he didn’t have one though). The appellant in fact complied for reasons which he explained. (3) The penalty letter says that an ineligible claim was submitted. That can only be determined after and not before the process of contesting the rejection, including where necessary up to the tribunal, is complete. (4) No explanation is given of why the submission of an ineligible claim means that the claimant is liable to a penalty under Schedule 24 FA 2007. What HMRC must show is that there is an inaccuracy in the claim and that that inaccuracy amounted to, or led to, a false or inflated claim to payment of tax and that the inaccuracy was careless or deliberate on the claimant’s part. Nothing of the sort was shown. (5) Because of that, any claimant receiving such a letter might reasonably refer back to the claim form VAT431NB. There in the declaration at item 24 a claimant is told that HMRC may charge a financial penalty for giving “ incomplete or inaccurate” information in the claim, and that they may be prosecuted for the same cause. Had the appellant in this case anxiously re-examined his claim form, we cannot see what he would have found in the form as submitted that he could on reflection have regarded as inaccurate, except for one thing – he said “yes” to the question (13) whether the terms of his planning permission prevented (the form’s odd use of that verb, not the appellant’s) disposal separately from any other pre-existing building. Nothing however was incomplete. What then concerns us particularly is the possibility that HMRC had seized on this inaccuracy and would for that reason impose a penalty, much as they did in C J Palau & R C Loughran v HMRC [2015] UKFTT 38 (TC) , that was, for the reason given in that case, simply wrong-headed. [Our emphasis]. 143. To be fair to HMRC however, it seems that they did not in fact notice the incorrect answer, because had they done so they would surely have given that as their reason for rejecting the claim in much more clear and forthright terms than they actually used. So the inaccuracy must be sought for elsewhere. Unfortunately it seems that the inaccuracy on which HMRC would rely is simply the rejection by them of the claim, as if it was self-evident that there must be an inaccuracy within the meaning in paragraph 1 Schedule 24. It is not. No question in the form relates to whether the construction was in accordance with the planning consent [5] . Question 12 asks whether planning permission had been obtained, to which the appellant’s truthful answer was “yes”. Under the question itself the form says:
“To obtain a VAT refund you must provide evidence that the works are lawful and send to us a copy of the Planning Permission.” 144. The appellant sent the planning permission. The word “lawful” here is clearly meant to be a reference to s 35(1)(b) VATA [6] , and can only we think be a reference to whether planning consent had been obtained, given the words used immediately after it in Question 12. It is surely not meant to be a requirement on the claimant that he self-certifies that he actually did everything and no more than the planning permission required whether explicitly or by implication, which is what HMRC’s submissions in this case amount to. 145. Despite the decision letter revealing no inaccuracies, the penalties letter said that HMRC required information to establish how the inaccuracies came about. One of the pieces of information required was “Please explain why you consider your claim to be eligible under the DIY scheme?”
If HMRC could not understand from the claim form why the appellant thought he was eligible, then surely the action should be questions to the appellant to establish it, not an unreasoned rejection of the claim. 146. The claimant was also asked for details of any “exceptional circumstances or information” they feel to be relevant. How any claimant is expected to know what circumstances are exceptional in this context or what information that HMRC did not have was relevant we cannot fathom. 147. That these questions are singularly unhelpful can be seen from the appellant’s reply, by return of post, as requested. On the matter of why he thought he was eligible for a refund, the appellant simply pointed to his letters of 31 January 2017 (the covering letter with the claim) and his reply to the rejection letter of 3 May. He said that he didn’t believe there were exceptional circumstances because he had complied with HMRC advice – here the appellant has not realised that what HMRC had in mind (we think) is that there may have been exceptional circumstances which excused the inaccuracy. 148. It is unnecessary and wrong for the recipient to be told, having been asked for relevant information without any clue as to what is or is not relevant, that they must not (the words “do not” are emboldened in the letter) include any details about their claim that are not relevant. 149. The recipient was given a factsheet CC/FS9 called “Compliance [misspelled by HMRC] Checks – Human Rights Act.” They are told in bold letters that when they respond they are to confirm in writing that they have received, read and understood the contents of the factsheet. The factsheet explains the appellant’s right to silence. 150. The letter says that if the recipient did not reply in writing by the 30 th day after the date of the letter a decision would be made and HMRC would write. It doesn’t say what would happen if the recipient did reply by then, ie what the next step would be. Common sense, elementary politeness and good customer service would suggest that any response, particularly one by return of post, should elicit a response from HMRC either seeking further information, saying that a penalty would be issued or saying that no penalty would be issued. None of those things happened. 151. The appellant in his SoC brought the Tribunal’s attention to the penalties letter while admitting it did not have a direct bearing on the issues in the appeal. He pointed out, as we have done, that the letter was issued despite the fact that he had not had an opportunity to respond to HMRC’s rejection of his claim. The effect of it was to exert pressure on him not to pursue the claim. He says his family were against contesting the matter because of the threat by the government to prosecute and they exerted pressure on him to drop the mater for fear of prosecution. This placed him under extreme and unnecessary pressure. This type of threatening correspondence was, he says, tantamount to intimidation and should not have been issued by HMRC until all of his arguments were at least recorded. 152. We agree with the appellant. Decision 153. In relation to the DIY Builders scheme in s 35 VATA, the only appealable decision is one with respect to the amount of any claim (see s 83(1)(g) VATA). HMRC’s decision was that the amount was nil. As we have upheld the appeal it falls to us to say what the amount of the successful claim is, and it is therefore £12,731.62 (Item 21 on Form VAT431NB) that amount which falls to be repaid. It is irrelevant that HMRC purported to reserve the right to scrutinise the individual invoices should the appeal succeed: it is too late for that. This was established in Lady Henrietta Pearson v HMRC [2014] UKFTT 890 (TC) (Judge Howard Nowlan and Mr Richard Thomas). That was the decision in the second appeal in the case and arose because after Lady Pearson’s claim was upheld on appeal in the 2013 decision (see §§106 to 109) HMRC had attempted to reduce the amount claimed on the grounds that the 5% reduced rate should have been charged on the goods acquired by Lady Pearson. The Tribunal held that to be an illegitimate attempt to reopen the appeal. Costs 154. It will be apparent from what has gone before that we were not impressed, to put it mildly, by HMRC’s conduct of this case up to the hearing. We think we should let Mr Swales know that although in the normal run of things in appeals to this Tribunal each party meets their own costs, an exception can be made if the Tribunal considers that a party has acted unreasonably in bringing, defending or conducting the proceedings. The “proceedings” here start when the appeal is made to the Tribunal, so it is only costs incurred after that which can be paid by one party to the other, but the conduct of that party before the appeal may be considered when deciding it was unreasonable. 155. We know of course that the appellant acted in person and is retired, so that the amount of expenses incurred may not be enormous. We therefore leave it to the appellant to decide if he wants to make an application for costs. If he does then he should set out why he thinks HMRC’s conduct was unreasonable and send his application to the Tribunal within 28 days of the date of release of this decision. He should also send a copy to HMRC and we will give HMRC the opportunity to make representations. Once we have them we will make a decision. We should stress that it is by no means certain that we would award costs to the appellant: it depends on our view of what he says and what HMRC say. 156. 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. RICHARD THOMAS TRIBUNAL JUDGE RELEASE DATE: 25 April 2019 [1] Despite the space in the regulations the form calls itself “VAT431NB”. [2] It is not clear to us what his actual decision was. [3] Given the way the DIY team works, by reference exclusively to the VAT Notice and its own guidance, it is likely to be an indirect and unintended reference to those Notes. [4] We observe that HMRC are in something of a cleft stick over annexes. A liberal view of what is an annexe will limit the ability of a claimant to establish that a building is a new build, unless the claimant is a charity in which case a narrow view will limit the extent of the exception in Note 17. [5] Judge Thomas has been here before: see Howells & Anor v Revenue & Customs [2015] UKFTT 412 (TC) . [6] We do wonder why it is in s 35 VATA at all. There is no reference to “lawful” in Items 1 to 4 of Group 5, but Note 2(d) still applies.

Cited in 3 later judgments