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HMRC internal manual

VAT Fraud

The Kittel principle intervention: Introduction

You should have:

  • carefully and fully documented the way the market in which the taxable person operates and his business model (VATF32100);
  • carefully and fully documented how the taxable person carries on his business (VATF32200 and VATF32300);
  • determined whether there has been a supply for VAT purposes (VATF34000);
  • checked the credibility of the transactions and the taxable person (VATF33000); and
  • thoroughly examined the documents used to evidence the transaction and the circumstances surrounding the transaction.

You should also have considered whether to apply an intervention (VATF40000).

In addition to the interventions explained in VATF40000 this section explains when and where to apply the Kittel principle for transactions ‘connected with fraudulent evasion of VAT’ and where we can evidence that the taxable person ‘knew or should have known’ of that fact.