Till roll issues

HMRC’s use of best judgment

The taxpayer traded as an off-licence and grocery business. During a VAT compliance visit in February 2013 officers asked him to retain till rolls for a later review. In an unannounced visit a few days later the officers took away two till rolls for analysis and found that the ‘no sale’ button had been used on what they considered an ‘excessive number of occasions’. They concluded that he was making several off-record sales when he entered customers’ cash in his till but not recording them as positive sales in his accounts. HMRC raised an assessment for £101 550 for the periods 11/09 to 5/13.

The taxpayer was unable to explain the excessive number of ‘no sales’. The First-tier Tribunal was satisfied that he had been suppressing his sales and agreed with HMRC that the number of no sales recorded was much higher than...