Section 84(4E)

Where an appeal is brought against a requirement imposed under paragraph 4(2)(b) of Schedule 11 that a person give security, the tribunal shall allow the appeal unless HMRC satisfies the tribunal that— there has been an evasion of, or an attempt to evade, VAT in relation to goods or services supplied to or by that person, or it is likely, or without the requirement for security it is likely, that VAT in relation to such goods or services will be evaded.

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Source: legislation.gov.uk · retrieved 2026-07-28