V4.302 Proof of export, time limits and declaration procedures
Proof of export
HMRC states, in Notice 703 (October 2017) that a supplier must obtain commercial or official proof of export which clearly identifies the exporter, the customer, the goods, the export destination, the mode of transport and the route taken1. These requirements are the means by which HMRC is satisfied both that goods have been exported or shipped abroad and that the conditions attached to zero-rating described in V4.301 have been met. To the extent that a value must be shown on a document required to be held as proof of export, the document is invalid if a false value is shown. Consequently the conditions for zero-rating are not met and zero-rating may, subject to the discretion of HMRC, be denied2.
HMRC's requirements for proof of export to obtain zero-rating have been upheld in the Court of Appeal3. Zero-rating was similarly denied on an export in the absence of HMRC's required proof of export in Stockton Plant & Equipment Ltd v C & E Comrs (1986) VAT Decision 2093. It was also denied, in A & S Import And Export Trading v HMRC  UKFTT 14 (TC), TC07520, where the Tribunal held that 'it is not a requirement [of Notice 703 para 6.54] that all the necessary evidence of export needs to be contained in a single document in each case. However, the fundamental problem that we encountered is that it was simply not possible, on the basis of the evidence
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