Summary 

The appellant’s main business activity was the provision of domiciliary care in patients' homes. It had not previously registered for VAT because it was CQC-registered and so those supplies were exempt from VAT. The VAT registration on 1 April 2019 was requestedbecause the appellant had begun to provide consultant advice and training within the care sector. HMRC ruled that the appellant had been in receipt of supplies of staff from an overseas supplier and had failed to account for VAT under the reverse charge. 

Background 

In 2015 the appellant began to work with a Slovak entity (Atena). During the acquisition of the appellant by another company (Trinity) in 2021, advisers noted that the appellant may not have correctly accounted for VAT in respect of its business relationship with Atena. Trinity'