Plat UK Limited v The Commissioners for HMRC
Decision date: 2 July 2026
Neutral citation: [2026] UKFTT 999 (TC)
Overall AI summary confidence: high
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
Plat UK Ltd appealed HMRC assessments of £470,894 for input VAT claimed in periods 11/20–08/23. The Tribunal found Plat did not hold valid VAT invoices when it made the returns because the later-supplied Harrods/Selfridges documents lacked a sufficient description of goods and most invoices were not made out to Plat. HMRC reasonably refused to exercise its regulation 29(2) discretion to accept alternative evidence, and the appeal was dismissed. Permission to apply for appeal was noted.
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: high
The enforceable ratio is that a taxable person must hold a valid VAT invoice at the time of claiming input tax; an invoice must itself contain a sufficient description to identify the goods (regulation 14(1)(g)), and later-obtained supplier documents do not automatically cure an earlier defective claim. Regulation 29(2) permits HMRC to accept alternative evidence, but HMRC may reasonably decline that discretion where the available evidence leaves doubt as to who was the recipient of the supply.
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 (obiter) that treating separate retailer documents (e.g. till receipts plus later-issued documents) as a single composite VAT invoice is problematic because the statutory scheme contemplates the invoice requirement in a single document; that common retail practices of issuing retrospective business invoices may not change the VAT accounting where the original sale was a retail supply; and that obtaining invoices only after HMRC contact can undermine an input-tax claim.