Procedures followed

The Good Food Company registered for VAT in May 2004 in the name of the taxpayer who claimed to have no knowledge of the application or the business.

It received about £137 880 in VAT repayments which HMRC were unable to validate. The department raised assessments that would have largely cancelled out the repayments.

The taxpayer appealed on the basis the registration was fraudulent and she had not been in business as the Good Food Company. The Revenue accepted that her partner had completed the application fraudulently without her knowledge but added that the registration was valid.

The First-tier Tribunal decided HMRC were correct to register the taxpayer for VAT. The application included bank account details and relevant details about the business giving the tax department no reason to doubt that the VAT1 form was fraudulent.

There was no statutory requirement for HMRC to carry out...