This was an appeal against a decision by HM Revenue and Customs (HMRC) to disallow claims for recovery of input tax on the basis that the corresponding invoices held by the appellant did not meet the relevant legislative requirements, namely that the description of the services provided was not detailed enough for HMRC to establish the liability.  

HMRC argued that HMRC needed to be able to verify that the details on the invoices were correct, that the VAT had a business purpose and was charged at the correct rate. HMRC suggested that the description was insufficient as it did not allow HMRC to assess the liability or determine the rate of VAT due. 

The appellant contended that an invoice could have a simple description and “did not need a novel” in order for it to be valid. 

The First-tier Tribunal (FTT) considered that the purpose of the description required by the statute was twofold: 

(1);