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Your nemesis

18 November 2010
Issue: 4282 / Categories: Tax cases
Connect Global Ltd v CRC, Upper Tribunal (Tax and Chancery Chamber)

HMRC use international mobile equipment identity (IMEI) numbers to identify individual mobile phones and keep the information in a database called Nemesis.

HMRC refused the appellant company’s input tax claim for April 2006 because it did not record IMEI numbers and this could be an indication of missing trader intra-community fraud.

The taxpayer appealed.

The taxpayer claimed that it did in fact keep IMEI numbers which could be provided if required while HMRC’s statement of case relied on the fact that there was no recording of IMEI numbers.

Evidence provided on the taxpayer’s behalf was considered by the tribunal to be incomplete so it directed that both parties must confirm by March 2010 that they had disclosed all the documents on which they intended to rely or which were relevant to the issues in the appeal.

The Revenue wrote to the taxpayer asking...

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