UK tribunal explains Unatrade’s input-VAT evidence failure in full reasons

The dispute concerned luxury goods bought from UK retailers and exported to Hong Kong. HMRC denied 90% of the input-tax claims for July–November 2023 because Unatrade lacked valid invoices or satisfactory alternative evidence. The full reasons do not impose a new general restriction on export input tax.^[1]

Alternative evidence remains possible

The framework is Value Added Tax Act 1994 section 24(6) and the Value Added Tax Regulations 1995, SI 1995/2518, regulations 13, 14, 16 and 29(2). A defective invoice does not automatically end the enquiry. The 2003 amendment to regulation 29(2) expressly permits evidence beyond documents; HMRC’s current guidance says staff should consider satisfactory alternatives rather than reject a claim simply because a compliant invoice is absent.^[1][2][3][4]

On these facts, calculating one-sixth of a receipt’s gross total did not show that VAT had actually been charged. Most documents lacked a VAT amount and none named Unatrade as purchaser. The tribunal concluded that a proper exercise of discretion would produce the same denial, so it did not determine whether the officer’s original approach had been flawed.^[1]

Match the evidence to the claimant and period

Groups should retain proof of VAT charged to the claimant and connect each document to the correct period. A taxable purchase or onward zero-rated export does not itself replace that evidence. The decision preserves alternative-evidence discretion; it does not create a new general filing or payment deadline. It separately states the parties’ usual permission-to-appeal limit as 56 days after the decision is sent, not automatically 56 days from its release date.^[1][3][4]