Ravenfield Limited v Commissioners for Her Majesty's Revenue and Customs

Decision date: 30 July 2010

Neutral citation: [2010] UKFTT 359 (TC)

Overall AI summary confidence: high

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Short overview

This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.

AI confidence in this short overview: high

Ravenfield Limited appealed HMRC's refusal to allow input VAT of £21,214.91 on a Bentley GT Continental used in its hire business. The First-tier Tribunal, proceeding in Ravenfield's absence, found the documentary evidence insufficient to prove the car was acquired and used exclusively or primarily for taxable business purposes under article 7 of the VAT (Input Tax) Order 1992. The appeal was dismissed and the input tax credit denied.

Ratio decidendi

This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.

AI confidence in this ratio decidendi summary: medium

A claimant seeking input tax credit for a motor car subject to the 1992 Order bears the burden of proving the vehicle was acquired and used for qualifying business purposes; where use is in issue, contemporaneous documentary evidence (e.g. hire contracts, insurer payments, deposits, mileage checks, or other corroboration) may be necessary to discharge that burden.

Obiter dicta

This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.

AI confidence in this obiter dicta summary: medium

The tribunal observed it would have been straightforward for Ravenfield to produce evidence of insurer payments if such payments had been made, and expressed scepticism that a business conducting prestige self-drive hires would not use standard contractual and payment safeguards.