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HMRC internal manual

VAT Fraud

The Kittel principle intervention: Overview: The three ‘limbs' of the Kittel principle

The Kittel principle can be broken down into three ‘limbs’, as follows:

  1. Was there fraudulent evasion of VAT? (VATF53100)
  2. Was the transaction ‘connected with’ that fraudulent evasion of VAT? (VATF53300)
  3. Did the taxable person, when he entered into the transaction, know or should he have known that it was ‘connected with fraudulent evasion of VAT’? (VATF53400)

When and where to apply the Kittel principle is looked at in VATF52400.