In VAT (unlike direct tax), disputed amounts have to be paid to HMRC pending the outcome of any appeal, unless the taxpayer can demonstrate that it would cause them serious financial hardship to do so. VATA 1994 requires payment to be made (or hardship to be claimed) before an appeal can be “entertained”. The courts have historically considered that an appeal is entertained when a hearing date is fixed (i.e., after documentary evidence has been finalised, and witness statements exchanged).
Source Deloitte
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