No chance of success

HMRC presented a creditor’s petition in April 2014 for the winding-up of a company on the ground it owed corporation tax of about £239 000.

The firm appealed to the First-tier Tribunal (Tax) and applied for the petition to be dismissed arguing that the tax liability was in dispute.

The petition was amended by the Revenue to cover a VAT liability of £1.6m. The department said the company had not paid input tax claimed and was therefore not entitled to set off it against the output tax for which it was liable. This was known as the non-payment issue.

The business appealed against the assessment and applied to have the petition dismissed because the VAT was not agreed.

HMRC made more amendments to the petition to take account of other assessments. The tax authority said no supply existed to allow the company to justify the inputs claimed ...