Second assessment out of time

The first issue in this appeal concerned the liability of the taxpayer’s sales – supplying cosmetic services to patients. The First-tier Tribunal followed the decision reached in other recent tribunal cases that they did not qualify for exemption as a medical service designed to improve maintain or prevent ill health see for example Illuminate Skin Clinics Ltd (TC8846) reported in Taxation 20 July 2023. The sales were therefore standard rated and HMRC was correct to register the business for VAT.

The second issue was whether an assessment issued by HMRC on 18 March 2021 for £212 897 in relation to the VAT period ending 28 February 2018 was out of time because the assessed period was more than two years before the issue date.

The business was compulsorily registered for VAT by HMRC on 1 May 2017...