This was an appeal by the taxpayer against an assessment by HMRC for underdeclared output tax. 
 
HMRC assessed the appellant for over £900,000 on 100% of the sums of money it had received from students/clients whereas the appellant contested that VAT was only due on the commissions it received. In the alternative, the appellant argued that the assessment had been wrongly calculated as a number of clients were from outside the EU.  
 
The appellant’s business was essentially Internet-based. The appellant traded under various names, one of which was ‘UK Essays.com’, and those who would like to have an essay, dissertation or piece of coursework written for him/her could go onto the appellant’s website.  
 
The First-tier Tribunal (FTT) saw a hard copy of the website and was able to see that a potential client could choose a particular kind of service