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Beyond Kittel: When HMRC Alleges the Taxpayer Was the Fraudster

HMRC is increasingly alleging not just that a taxpayer knew about fraud, but that it actively participated in or orchestrated it. We explain why that distinction changes everything.

26 June 2026By Liban

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HMRC Rejecting COP9 Applications: What to Do if Your CDF Outline Disclosure Is Refused

HMRC is rejecting some COP9 applications at Outline Disclosure stage, especially in smaller cases. Learn why CDF applications are refused and what taxpayers should do next.

When Clients Meet AI

AI can surface a legal authority in seconds, but knowing whether it is still good law, binding, and genuinely on point is where research ends and judgment begins.

Why Are More Businesses Winning Kittel Appeals Against HMRC?

HMRC once dominated Kittel litigation, but taxpayers are now winning far more VAT fraud appeals. We examine what has changed and why specialist representation matters.

HMRC CIS Supply Chain Fraud Investigations: The Kittel Principle Arrives in Construction

HMRC has introduced significantly stronger powers targeting CIS supply chain fraud. Contractors facing FIS enquiries may increasingly encounter "knew, or should have known" allegations familiar from VAT Kittel litigation.

Kittel VAT Fraud – A Liquidator's High Court Claim

Analysis of the High Court judgment in Hellard v Khan regarding MTIC VAT fraud liability and personal penalties for directors.

Successful Kittel Tribunal Appeal 2025

A successful Kittel Tribunal appeal in 2025, demonstrating specialist expertise in MTIC VAT fraud cases.

How to win an MTIC Appeal

A comprehensive guide to winning MTIC and Kittel VAT Tribunal appeals, covering strategy, fees, and key principles.

Deliberate Allegation Test

The legal test for deliberate allegations by HMRC, including the requirement for dishonesty and the ongoing debate in the Upper Tribunal.

HMRC Compliance Check

Understanding HMRC compliance checks, your rights and obligations, and how proper representation can resolve enquiries quickly.

KITTEL/MTIC FRAUD – OUTSOURCING PAYROLL SERVICES

How criminals exploit outsourced payroll services through MTIC fraud schemes, the warning signs to watch for, and the serious consequences for businesses.

The Challenges of Defending MTIC (Kittel) Fraud Allegations

16 strategic pointers from 16 years of experience in defending MTIC Kittel fraud allegations at tribunal.

HMRC Kittel Investigations – Early Intervention Essential

Case study demonstrating why early specialist intervention in HMRC Kittel investigations is essential, before HMRC reaches its decision.

HMRC Site 'Careless' Behaviour to Avoid Being Time Barred

CTM successfully challenged a £600,000 Discovery Assessment where HMRC alleged carelessness to extend the statutory time limit after missing its own deadline.

The Kittel Principle

A comprehensive guide to the Kittel Principle, its historical context, modern application, and CTM's 18 years of experience handling over 100 Kittel cases.

VAT Status – CT Scans

CTM successfully defended consultant doctors against HMRC's position that CT scans were standard-rated for VAT, securing VAT-exempt status.

Import Duty Tribunal Appeal

How CTM successfully represented a major UK timber importer in a customs classification dispute, quashing a £275,000+ assessment.

MTIC Fraud Appeal – Airtime

First-Tier Tribunal appeal for PTGI-ICS Limited, where approximately £19.2 million in denied input tax was successfully challenged over a 13-day hearing.

MTIC Fraud – Outsourcing Payroll Services

How outsourced payroll services can become linked to MTIC fraud, resulting in substantial VAT assessments and personal director liability.

MTIC Fraud Tribunal Success

CTM represented Ulster Metal Refiners Limited in a soft drinks MTIC case, successfully recovering approximately £420,000 of denied input tax.

Personal Liability Notice

CTM is the most successful firm overturning Personal Liability Notice decisions at Tribunal, with two notable case studies demonstrating effective defence strategies.

Mecsek

Analysis of the Mecsek Doctrine and its application in M&M (Cambridge) LLP's export transaction tribunal case.

MTIC Analysis

Analysis of the landmark Mobilx Limited v HMRC Court of Appeals case on MTIC fraud and the 'should have known' test.

Relying on an Agent

Successful tribunal appeal against careless penalty where a competent accountant made an error - the penalty should apply to the agent, not the taxpayer.

PLN Analysis

Analysis of Auxilium Project Management Limited v HMRC on deliberate penalties and the five critical points arising from the case.

PLN Analysis 2

Analysis of Darren Cresswell's successful challenge against HMRC penalty liability notices totaling over £208,000.

COP9 Procedure

How the COP9 disclosure process works and what it means for individuals who have committed tax fraud.

General Disclosures of Fraud

An alternative to COP9 for declaring tax fraud to HMRC, and when each route is most appropriate.

HMRC Time to Pay Arrangements

How to negotiate time to pay arrangements with HMRC and why professional guidance can make a significant difference.

Restoration of Seized Goods

What to do when goods are seized by Border Agency and how to pursue restoration through review and tribunal appeal.

Zero-rated VAT on Digital Services HMRC

Clarifying the misconception about zero-rated VAT on digital services following the Chancellor's autumn 2019 Budget.

Can you Appeal a Tax Tribunal Decision/Judgement?

Understanding the process and realistic timelines for appealing a Tax Tribunal decision.

Cross-Examination of Witnesses

How cross-examination works in tax tribunal hearings and why it is essential to challenge disputed evidence.

Serving Evidence/Documents Late

Why late service of evidence should be avoided and how to properly prepare documents for tribunal hearings.

Striking Out an Appeal

Understanding how tribunal appeals can be struck out for non-compliance and what steps can be taken to prevent it.

The Normal Tribunal Appeal Process

A guide to the three categories of tribunal appeals and the procedural steps involved in each.

What to expect at a Tax Tribunal Hearing?

A practical guide to what happens at a Tax Tribunal hearing, designed to put minds at rest.

Appeal the Tax Assessment, not just the Deliberate Penalties

A critical lesson about appealing tax assessments alongside deliberate penalties to preserve your rights.

HMRC Activity During Coronavirus Outbreak

How HMRC operations were affected during the coronavirus pandemic and the impact on taxpayers.

Fraud in Customer Chain (Mecsek-Gabona Kft)

ECJ case extending the Kittel principle to export transactions and zero-rating claims.

Liquidators Action Against Directors

HMRC increasingly appoints private insolvency firms when winding up companies for unpaid taxes.

Outsourcing Payroll Services Linked to MTIC Fraud

How MTIC fraud principles apply to outsourced payroll services and the risks businesses face.

Personal 'Deliberate' Penalties

HMRC can issue personal penalties to directors and accountants without establishing fraud.

CTM Success in VAT Security Appeal

Tribunal victory for a Mexican restaurant regarding a VAT Security Notice issued due to prior arrears.

De-registration of VAT numbers unlawful at times

HMRC frequently de-registers businesses but cannot do so lawfully in all circumstances.

MTIC Fraud News

The First-Tier Tax Tribunal is becoming more tolerant with traders in MTIC fraud appeals.

Repayment Supplement when HMRC repay VAT late

HMRC must provide a 5% supplement when VAT repayments are delayed beyond the statutory timeframe.

Tribunal's Hands Tied in Certain Cases

Tribunals sometimes lack direct decision-making authority in excise cases and must defer to HMRC review procedures.

Research and Development

HMRC's stricter approach to R&D tax relief claims and what businesses need to know about successfully submitting them.

Time to Pay Arrangements

Understanding HMRC's Time to Pay arrangements and how to negotiate manageable payment schedules.

VAT Security

Understanding HMRC's Notice of Requirement to Give Security and how to respond to protect your business.

HMRC 'Best Judgement' Assessments

Understanding HMRC's power to issue 'best judgement' assessments and how to challenge inflated figures.

Late Appeal to Tax Tribunal

Guidance on making late appeals to the Tax Tribunal, including the five key principles from case law.

Recovering Legal Fees if Successful on Appeal

Can you recover legal costs after winning a Tax Tribunal appeal? Understanding Rule 10(1)(b) and unreasonable conduct.

Drilling rigs can use red diesel

CTM Law successfully challenged HMRC's interpretation of red diesel usage rules for vehicles transporting drilling rigs.

HMRC Debt Recovery

How HMRC pursues tax debts and what you can do to challenge incorrect assessments.

HMRC Pleadings in Fraud Cases

Court of Appeal ruling on how HMRC must properly plead fraud cases, following the Ulster Metal decision.

HMRC Raising Tax Assessments Out of Time

Understanding HMRC's time limits for raising tax assessments and how to challenge out-of-time assessments.

Personal Penalties

Understanding HMRC's power to raise personal penalties against directors for deliberate tax defaults.