Summary 

The appellant had appealed to the First-tier Tribunal (FTT) against an assessment to VAT on the grounds that it had a legitimate expectation that it would not be assessed to VAT on certain supplies. It said that its legitimate expectation arose from statements made by HMRC. The FTT dismissed its appeal, finding that the appellant could not rely on the principle of legitimate expectation because it had not acted reasonably in relying on HMRC’s statements. The appellant appealed to the Upper Tribunal (UT). 

Background 

The appellant belonged in Poland for VAT purposes. It entered into a contract with Energoinstal SA, another company based in Poland, to install a boiler in the UK. Energoinstal was not registered for VAT in the UK. The appellant considered that it should register for VAT in the UK. It applied to