Early supplies

The taxpayer applied in January 2013 to be registered for VAT with effect from 14 October 2012.

HMRC paid a VAT visit after the submission of his first return (for the period to 31 May 2013). The officer confirmed that the taxpayer was correct not to claim in respect of helicopter pilot training he underwent between November 2011 and March 2012 because the invoices were dated 2011. Input tax cannot be recovered on services supplied to the taxable person more than six months before the VAT registration date.

The taxpayer nevertheless claimed on pilot training in his August 2013 return on the ground it constituted a supply of goods the window being four years from the date of registration.

The Revenue disallowed the claim saying the training was a supply of services. The department also imposed a penalty under VATA 1994 sch 24 on the...