This was an appeal against three decisions by HM Revenue and Customs (HMRC) resulting in assessments, including penalties, of over £8.3 million.  
    
The decisions related to input tax claimed on the purchase of precious metal (platinum and palladium). HMRC’s primary case in relation to these decisions was that the transactions concerned were ‘connected with a fraudulent evasion of VAT’ and that the appellant, ‘knew or should have known that this was the case’. An additional, alternative, case advanced by HMRC at the hearing was that the appellant knew or should have known that the transactions were not consistent with a genuine commercial market and were therefore connected to fraud in general.  
 
Background 
 
The transactions with which this appeal is concerned relate to the purchase of precious metals by the