VAT – denial of input tax relief – connection with fraud – Vanrooyen

“We were satisfied HMRC had established fraudulent tax losses and that there was an orchestrated scheme for the fraudulent evasion of VAT connected with the transactions which form the subject of this appeal.

We concluded that in respect of the period under appeal that the Appellant knew that the transactions were connected with the fraudulent evasion of VAT or that the factors set out above would at the very least support a finding of means of knowledge and that the Appellant did not take every reasonable precaution within its power to prevent its own participation in that fraud.”