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HMRC internal manual

VAT Fraud

HM Revenue & Customs
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The Kittel principle intervention: Overview: When and where to apply the Kittel principle

You can consider applying the Kittel principle to any claim for input tax irrespective of:

  • the type of transaction being undertaken (e.g. whether they are goods or services or what those goods or services are);
  • where in the transaction chain the taxable person is (e.g. whether they feature as a broker, buffer, contra etc (VATF23500));
  • whether the VAT return is a net payment to or repayment from HMRC; or
  • where the fraudulent evasion of VAT occurred (VATF53110 and VATF53115).