Summary 

This was an appeal to the First-tier Tribunal (FTT) against an assessment for £496,823 for undeclared output tax. The appellant was a retailer of flooring, including carpets, underlay, vinyl and wood flooring. A customer who purchased flooring from the appellant was given the option to have an independent, self-employed fitter to carry out the fitting of the flooring that the customer had purchased. If the customer so chose, the fitter attended the customer's home to fit the flooring; the fitter was then paid by the customer for that work, with the money being received and retained, in full, by the fitter. HMRC decided that the appellant had incorrectly treated the supply of carpet fitting and contended that the appellant supplied fitting services via subcontractors as part of a single supply and assessed the appellant for output tax on the fitting fees.  

Background 

The