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You are here: BAILII >> Databases >> First-tier Tribunal (Tax) >> PS Gill & Son (UK) Ltd v Revenue & Customs [2012] UKFTT 374 (TC) (21 May 2012) URL: http://www.bailii.org/uk/cases/UKFTT/TC/2012/TC02058.html Cite as: [2012] UKFTT 374 (TC) |
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[2012] UKFTT 374 (TC)
TC02058
Appeal numbers: MAN/2007/00411
MAN 2008/00706
VAT – MTIC fraud – contra trading – whether fraudulent VAT evasion established – only in relation to some defaults – whether connection to fraud established – yes, both directly and through contra trader – whether Appellant should have known of the connection – yes – appeal dismissed |
FIRST-TIER TRIBUNAL
TAX CHAMBER
|
P S GILL & SON (UK) LIMITED |
Appellant |
-and-
|
THE COMMISSIONERS FOR HER MAJESTY’S REVENUE AND CUSTOMS |
Respondents |
TRIBUNAL: |
KEVIN POOLE (TRIBUNAL JUDGE) PETER WHITEHEAD |
Sitting in public in Birmingham on 10 to 16 May 2011 with subsequent written submissions
Tim Brown (instructed by Tax & Legal Services Limited) for the Appellant
Richard Chapman (instructed by Howes Percival) for the Respondents
© CROWN COPYRIGHT 2012
DECISION
(1) in PSG’s VAT accounting period for the month of April 2006 (period 04/06), the purchase on 26 April 2006 of 5,000 Nokia 8800 and 7,000 Nokia N90 mobile phones for a total price of £3,721,000 plus £651,175 of VAT from Kingswood Trading Services Limited (“Kingswood”, which in this decision also refers to the other companies managed by Ian Tuppen with which PSG traded over the relevant period), which phones were sold by PSG to 2Trade BVBA of Belgium (“2Trade”) on the same day for £3,869,500 (free of VAT);
(2) in PSG’s VAT accounting period for the month of May 2006 (period 05/06):
(a) the purchase on 25 May 2006 of 5,000 Nokia 9300i, 3,750 Nokia N70 and 2,000 Nokia 8800 mobile phones for a total price of £2,749,250 plus £481,118.75 of VAT from Kingswood, which phones were sold by PSG to 2Trade on the same day for £2,859,875 (free of VAT);
(b) the purchase on 30 May 2006 of 2,400 Nokia 8800, 3,000 Nokia 9500 and 3,500 Sony Ericsson W810i mobile phones for a total price of £2,497,100 plus £436,992.50 of VAT from Kingswood, which phones were sold by PSG to 2Trade on the same day for £2,597,100 (free of VAT); and
(1) Joseph Baines (responsible for verifying PSG’s VAT returns and associated VAT repayment claims which are the subject of this appeal);
(2) Michael Donald Phipps (PSG’s control officer for most of the time from May 2003 to April 2006);
(3) Sarah Jane Barker (responsible for verifying the VAT return of Crestview Enterprises Limited (“Crestview”), the alleged contra trader, for its VAT accounting period from 1 April to 30 June 2006);
(4) Peter Goulding (in relation to the alleged defaulter C and B Trading (UK) Limited (“C&B”));
(5) Vivian Barbara Parsons (in relation to the alleged defaulter RS Sales Agency Limited (“RS Sales”));
(6) John Michele Christopher Cordwell (in relation to the alleged defaulter Red Rose Consultancy (UK) Limited (“Red Rose”));
(7) Barry Michael Patterson (in relation to the alleged defaulter Zenith Sports (UK) Limited (“Zenith”));
(8) Fu Sang Lam (in relation to the alleged defaulter West 1 Facilities Management Limited (“West 1”));
(9) David Kenneth Leach (referring to and commenting on a witness statement of Officer David Skelly, who had since left HMRC, concerning an earlier disputed claim of PSG for a VAT repayment);
(10) Terence Mendes (in relation to First Curaçao International Bank NV (“FCIB”));
(11) David Young (in relation to FCIB’s Paris server information);
(12) Andrew Leatherby (in relation to IP address logging); and
(13) Guy Roderick Stone (in relation to MTIC generally and in relation to Ian Tuppen of Kingswood).
10. We also received a witness statement from Sukhdev Singh Gill (“Mr Gill”), the managing director of PSG. He had previously carried on PSG’s business as a sole trader and, before that, in partnership with his father and brother.
11. At the hearing, Mr Gill gave extensive oral testimony and the following HMRC officers also gave oral testimony: Mr Phipps, Mr Baines, Mr Leach and Mr Mendes (who, by agreement between the parties, gave some evidence about “Redhill verification” procedures as well as being cross examined on his evidence in relation to FCIB).
(2) PSG’s VAT registration number is 112 6012 33.
(3) The Business, with its VAT registration number, had originally begun as a sole proprietor under the name of Mr Piara Singh, trading as PS Gill and Sons. In the original VAT1 the main trade classification was selected as being code 8217 – girls’ wear and household textiles.
(4) With effect from 1 April 1981, the Business became a partnership between Mr Piara Singh and his two sons, Mr Gill and Mr Inderjit Singh.
(5) With effect from 1 April 2004, Mr Gill became the sole proprietor of the Business.
(7) PSG stated on its VAT registration form dated 24 March 2006 that its estimated turnover in the following twelve month period was to exceed £1,000,000, that it expected [the VAT on] its purchases regularly to exceed the VAT on its taxable supplies and that it did not expect to be either buying from or selling goods to other EU Member States.
(8) PSG submitted VAT returns for the period 04/06 on or about 8 May 2006 and for the period 05/06 on or about 9 June 2006 (“the Returns”). The Returns were selected for in-depth verifications.
(9) By a decision dated 27 March 2007, Mr Joseph Baines (Higher Officer of HMRC) denied input tax claimed by PSG in the period 04/06 in the sum of £651,175. This related to six purchases of mobile phones from Kingswood which were combined into one sale to 2Trade.
(10) By a further decision dated 27 March 2007, Higher Officer Baines denied input tax claimed by PSG in the period 05/06 in the sum of £918,111.25. This related to seven purchases of mobile phones from Kingswood, which were combined into two sales to 2Trade.
(11) By a further decision dated 7 May 2008, Higher Officer Baines denied further input tax claimed by PSG in the period 05/06 in the sum of £879,243.75. This related to the purchase of computer processing units (“CPUs”) from Crestview, which PSG sold to Fone Link.
(12) The basis for each of these decisions was that Higher Officer Baines was satisfied that the transactions formed part of an overall scheme to defraud HMRC and that PSG knew or should have known that this was the case.
(13) PSG issued a notice of appeal against the decisions of 27 March 2007, which was served on 3 April 2007. The grounds of appeal are as follows:
“The Appellant denies that he deliberately or recklessly ignored factors which indicated or may have indicated that the transaction entered into formed or may have formed part of an overall scheme to defraud the revenue.”
(14) PSG issued a notice of appeal against the decision of 7 May 2008, which was served on 20 May 2008. The grounds of appeal are in the same terms as the appeal against the decisions of 27 March 2007.
(15) By an order dated 14 July 2008, the two appeals were consolidated and directed to proceed under the reference MAN/07/0411.
(16) Various orders for directions have been made, culminating in a consent order approved on 22 January 2010 (“the 2010 Order”) listing the hearing of the appeal and providing for consequential directions.
(17) The appeal was listed for fifteen working days commencing on 9 May 2011.
14. There was a large measure of agreement between the parties as to the law to be applied in this case. The basic law flows from the decision of the European Court of Justice in the combined cases of Axel Kittel v Belgium; Belgium v Recolta Recycling [2006] ECR 1-6161, as explained in the Court of Appeal’s judgment in the combined cases of Mobilx and others v HMRC [2010] EWCA Civ 517.
(1) A claim for the repayment or deduction of input tax may be denied where the trader knew or should have known that, by his purchase, he was participating in a transaction connected with the fraudulent evasion of VAT.
(3) Tribunals should not unduly focus on due diligence.
(4) It would be artificial only to look at the purchase in respect of which the input tax is to be denied. Surrounding circumstances and the totality of a trader’s deals should be considered.
(5) The relevant time of knowledge is the time of the trader’s transaction.
(6) In a contra transaction, the apparently clean chain need not pre-date the allegedly dirty chain.
(7) The burden of proof as to the state of the trader’s knowledge is upon HMRC.
(8) The standard of proof is the balance of probabilities.
(9) Circumstantial evidence of fraud of a sufficiently definite type will often indicate that a trader has chosen to ignore the obvious explanation as to why he was presented with an opportunity to reap a large and predictable reward over a short space of time.
“Insofar as contra-transactions where the evasion occurs post-date the Appellant’s transaction, HMRC must prove the Appellant ought to have known at the time of its transactions that another party was going to evade VAT at some point in the future.”
(1) the identity of the alleged fraudulent defaulter would not be known, which would mean that fraud on the part of that defaulter could not be established; and
(2) there was a real possibility that the amount of input tax denied to PSG would exceed the amount of VAT allegedly or actually unaccounted for by the defaulter, which would contravene the principle of fiscal neutrality.
20. We consider these submissions later in this decision, in the appropriate context
(1) All the deals in 04/06 (numbered 1 to 6 by HMRC) which PSG documented as one purchase from Kingswood and sale to 2Trade on 26 April 2006;
(2) Deals 5 to 8 in 05/06, which PSG documented as one purchase from Kingswood on 25 May 2006 and sale to 2Trade on 26 May 2006;
(3) Deals 1 to 3 in 05/06, which PSG documented as one purchase from Kingswood on 30 May 2006 and one sale to 2Trade on 31 May 2006; and
(4) Deal 4 in 05/06, which comprised a single purchase from Crestview and sale to Fone Link on 31 May 2006.
34. In a contra trading situation, HMRC must either:
(1) establish that the contra trader was acting fraudulently (in which case a clear “connection” to fraudulent VAT evasion within Kittel is easily established, the fraud in question being the contra trader’s fraudulent contra trading activity); or
(2) establish a connection with some other VAT fraud (which will generally need to be the fraud of a fraudulent defaulter at the beginning of a “dirty chain” leading up to the contra trader).
(1) Red Rose: £882,398.13;
(2) West 1: £350,962.50;
(3) Zenith: £351,750.00.
(1) There is a very real possibility that HMRC would be seeking to deny more input VAT than has actually been fraudulently evaded by the defaulter. This, they say, would be contrary to the fundamental principle of fiscal neutrality.
(2) It would not be possible to prove there has been a fraudulent VAT default. To prove fraud requires proof of the necessary mental element on the part of the perpetrator, and unless you have identified who the alleged perpetrator of the fraud is, that cannot be done.
“65. The Kittel principle is not concerned with penalty. It is true that there may well be no correlation between the amount of output tax of which the fraudulent trader has defrauded HMRC and the amount of input tax which another trader has been denied. But the principle is concerned with identifying the objective criteria which must be met before the right to deduct input tax arises. Those criteria are not met, as I have emphasised, where the trader is regarded as a participant in the fraud. No penalty is imposed; his transaction falls outwith the scope of VAT and, accordingly, he is denied the right to deduct input tax by reason of his participation.
66. It is not arguable that the principles of fiscal neutrality, legal certainty, free movement of goods and proportionality were infringed by the Court itself, when they were at pains to preserve those principles (see §§ 39-50). By enlarging the category of participation by reference to a trader’s state of knowledge before he chooses to enter into a transaction, the Court’s decision remained compliant with those principles.”
62. Red Rose was placed into liquidation on 21 February 2007.
Zenith continued to trade. On 19 June 2006, it carried out the sales to Coast Telecom to a value of £2,010,000 plus VAT which generated a £351,750 VAT liability which it has never settled. This is one of the defaults identified by HMRC as a fraudulent default in a dirty chain leading up to Crestview. This trade appeared to be a near exact repeat of an earlier trade on 8 June 2006, when it sold the same number and description of goods to Coast Telecom at the same price. In the earlier trade, its records showed it as having bought the goods from West 1 but in the later trade there was no record of Zenith’s supplier.
87. First, it is important to point out that it is not necessary for HMRC to show that PSG should have known of the details of the specific fraud (nor, therefore, of the particular connection to it) in each case. As Briggs J said in Megtian v HMRC [2010] EWHC 18 (Ch) at [37] to [38]:
“[37] In my judgment, there are likely to be many cases in which a participant in a sophisticated fraud is shown to have actual or blind-eye knowledge that the transaction in which he is participating is connected with that fraud, without knowing, for example, whether his chain is a clean or dirty chain, whether contra-trading is necessarily involved at all, or whether the fraud has at its heart merely a dishonest intention to abscond without paying tax, or that intention plus one or more multifarious means of achieving a cover-up while the absconding takes place.
[38] Similarly, I consider that there are likely to be many cases in which facts about the transaction known to the broker are sufficient to enable it to be said that the broker ought to have known that his transaction was connected with a tax fraud, without it having to be, or even being possible for it to be, demonstrated precisely which aspects of a sophisticated multifaceted fraud he would have discovered, had he made reasonable enquiries. In my judgment, sophisticated frauds in the real world are not invariably susceptible, as a matter of law, to being carved up into self-contained boxes even though, on the facts of particular cases, including Livewire, that may be an appropriate basis for analysis.”
88. To put it more succinctly, as Moses LJ said in Mobilx at [59]:
“The test in Kittel is simple and should not be over-refined. It embraces not only those who know of the connection [with fraud] but those who “should have known”. Thus it includes those who should have known from the circumstances which surround their transactions that they were connected to fraudulent evasion. If a trader should have known that the only reasonable explanation for the transaction in which he was involved was that it was connected with fraud and if it turns out that the transaction was connected with fraudulent evasion of VAT then he should have known of that fact. He may properly be regarded as a participant for the reasons explained in Kittel.”
89. In order to form a view of what PSG (through Mr Gill) should have known, it is therefore important to set these particular transactions in their proper context. As Moses LJ made clear, it is only by doing so that an informed view can be reached as to what PSG “should have known”. An examination of the context requires, as a first step, an examination of the trading history of PSG.
(a) Introduction and summary
90. The business currently run through PSG was started no later than 1 February 1975 by Mr Piara Singh Gill. The subsequent history of its structure is set out at [12(1)] to [12(6)] above.
(1) Up to December 2002, the business was averaging just under £121,000 of outputs per quarter; for the calendar year 2003, that changed to nearly £321,000 per quarter; for the calendar year 2004, it changed to over £2.75 million per quarter; for the calendar year 2005, in spite of a slow start it changed to £18.9 million per quarter; and in the first five months of 2006 it was running at a rate equivalent to an average of £77.3 million per quarter.
(2) The turnover was very erratic, especially from March 2003 onwards. Months or quarters generating sales of many millions of pounds were interspersed with months or quarters in which there were next to no sales.
(3) The general levels of sales in the “busy” months grew in early 2004 to a level of between approximately £0.5 million and £2.4 million. In the second half of 2004, it levelled off somewhat in the range £1.2 million to £2.6 million. During this period (in September 2004) PSG sold one batch of CF memory cards for export to Dubai to a value of £2.55 million (we heard evidence about this deal – see below).
(4) During the first five months of 2005, there was only one “busy” month (approximately £1.5 million of sales in February 2005). From June 2005 however, things accelerated rapidly, from £4 million to £13.6 million in September 2005.
(5) There were then just two large individual transactions (about which we heard some evidence – see below) in October/November 2005 and in January-March 2006, in which PSG traded some computer software to a value of some £100 million plus VAT, which it sold in an export deal to Dubai. These were the last deals before the deals in April and May 2006 which are the subject of this appeal.
(b) March 2003 deals
93. In March 2003 PSG commenced trading in electronic goods. Mr Gill’s evidence was that he had investigated the market intensively in 2002-03 and had attempted (unsuccessfully) to get chip manufacturers or authorised distributors to sell to him. He had a contact in Dubai (a Mr Showki) who ran a company called Data Easy, which dealt in such goods. Mr Showki told Mr Gill that he was interested in purchasing some memory chips if Mr Gill could source them at a competitive price. Mr Gill found a small UK supplier called Westpoint Services Limited in Cardiff via their website through a search engine, obtained some samples (which he had checked by a friend in the electronic retailing sector) and then bought and sold the goods for export to Dubai.
94. In his witness statement, Mr Gill gave evidence that he had done a second deal involving the same parties and double the quantity of the same product in May 2003. As before, he made a net profit of approximately £1 per chip, which satisfied him as he was new to the market. In fact, from records supplied by PSG to HMRC, it is apparent that this second deal took place also in March 2003, just eight days after the first deal. The combined value of the two deals was just over £300,000 plus VAT, and the records supplied to HMRC showed that PSG made exactly £1 gross profit per chip. HMRC subsequently traced Westpoint’s purchase of the chips back to a company called Risebrook Resources Limited, which officer Baines described as a “defaulting missing trader”.
(c) August 2003 deal
95. In or about August 2003, PSG carried out another trade in computer chips. It bought from a company called Redstar Marketing (GB) Limited (“Redstar”) in Llanelli (which Mr Gill said he had found through internet trading sites) and exported the goods to a company in Hong Kong called Vortex Technology Limited. The size of this deal was of the order of £200,000. Mr Gill said he had generated this deal himself by visiting Redstar and then offering the available chips to Vortex, a company he had made contact with as a result of his research.
96. HMRC’s records show that Redstar’s annual return to Companies House dated 28 March 2003 shows that its entire issued share capital was transferred on 25 November 2002 to one Shiao Chuan Yang of Taiwan (its sole director) and Redstar had two joint company secretaries (Tai Chim Lau and Yeung Tak Tang), with addresses in Swansea and Hong Kong. Mr Gill made no mention of any Chinese connections of Redstar known to him and he was not asked about it in cross examination, so it is not possible to read anything more than coincidence into this.
97. Mr Gill was clearly intending to expand the overseas trading of the business at this time. His advisers wrote to HMRC on 6 November 2003 requesting that the business be placed on monthly VAT returns as things had now changed so that the majority of sales were by way of export. HMRC placed the business on monthly VAT returns with effect from the period 01/04. It remained on monthly returns until 1 September 2007.
(d) November 2003 deals
98. In November 2003, the business sold three large consignments of clothing for export, having been approached by three different UK suppliers and three different EU purchasers (all of whom were previously unknown to Mr Gill) “out of the blue” within a very short space of time. The three deals came to a combined value of approximately £500,000. According to the notes of an HMRC visit to PSG on 17 May 2004, Mr Gill could not recall the names of any of the contacts he had dealt with at the three suppliers and three customers. He did not ask any of the three customers (Green Leaf in Spain, Negolux and Masters Trading in Luxembourg) how they had obtained PSG’s details. One of the deals related to leather jackets, a product in which PSG had not previously traded.
(e) First deal with Ian Tuppen’s companies – January and March 2004
99. There is some uncertainty about the date of Mr Gill’s first contact with Mr Ian Tuppen, the individual behind Kingswood and its associated companies. In his witness statement, Mr Gill said Mr Tuppen had contacted him “in January 2004”. References to contact with Mr Tuppen in other correspondence and in a meeting placed the date somewhat earlier. But whatever the date of that first contact, it appears that the first trading between the business and Mr Tuppen’s companies took place on 30 January 2004, when the business bought 21,600 “surface mounted semi conductors” from Mr Tuppen’s company for £473,040 plus VAT and sold them on to a company called Grantwell Limited in Hong Kong for £496,800. This was followed up by another trade of 43,200 semi-conductors on 25 March 2004 at a slightly lower unit price (bought for £915,840 plus VAT and sold for £961,200), with delivery initially required to Moscow (but subsequently changed to Dubai).
(f) April 2004 – first deal with United Kingdom Trading of Dubai
101. In a report of a meeting that took place between officers Furber and Skelley of HMRC and Mr Gill on 17 May 2004 (which was predominantly concerned with discussions about the clothing deals done in the previous November), there is a record of some discussion which also took place about a deal which PSG had done in April 2004. Some further detail about this deal also emerged from a report of a meeting between officers Phipps and Skelley of HMRC, Mr Gill and his tax advisers on 3 December 2004.
102. Mr Gill said that a “first time customer” had approached PSG to source some semi-conductors. It is apparent from the report of the 3 December 2004 meeting that this customer was United King Trading Company (“UKT”) in Dubai. Mr Gill said UKT had initially approached him with a letter of introduction, and he made no checks on them. In spite of this, he had sold them £1.6 million of semi-conductors sourced from Kingswood, allowing “14-20 days” of credit, on the strength of a phone call and the fact that UKT was based in Dubai, where Mr Gill considered the laws to be “strict”.
(g) September 2004 deal with UKT
105. Mr Gill explained to officers Phipps and Skelley on 3 December 2004 that Kingswood had approached him with an opportunity to sell the products, without discussing quantities. Mr Gill had contacted UKT and established they were interested. He spoke to someone called “Jane” there, but did not know her surname. When asked why he had not carried out any trades in the months from June to August 2004, he explained it was because he did not have the necessary finance to do so. He only lined up the September trade when he received the VAT repayment from HMRC from his May and June 2004 returns. As this was issued by cheque on 21 September 2004, this deal was therefore clearly arranged in a matter of a few days.
106. Mr Gill told the officers that he had “used the internet” to check on similar products in arriving at a selling price. He did not check prices on the manufacturer’s website.
108. On 15 October 2004, Mr Gill telephoned officer Phipps to enquire about progress on the verification. Officer Phipps asked Mr Gill if he could supply any further documents in relation to the sale; Mr Gill said he would try to obtain some and rang back later the same day to say he had received confirmation from UKT that the goods had been received in Dubai. This letter was faxed to HMRC the following day. It took the form of a letter from UKT dated 15 October 2004 with the following content:
“Dear Sir,
This is to inform that we have received the goods in proper order and good condition.
Thank you and best regards.”
109. In fact it is clear that this letter was giving inaccurate information. Officer Phipps only told Mr Gill of his information about the incorrectly described mobile phones when they spoke on 29 October 2004. In reply, Mr Gill said he had heard from UKT that they had not received the goods and he had requested their written confirmation of this. UKT sent a fax dated 19 October 2004 to PSG stating that their 15 October letter was “an error”, and that they had not in fact received the goods. The fax dated 19 October 2004 from UKT appears to have been sent only on 2 November 2004, along with two further communications bearing the dates 26 October and 2 November 2004, supposedly chasing up the delivery of the goods in increasingly assertive terms. However on 22 October 2004 PSG had received five BACS payments totalling just under £1.1 million from UKT and on 25 October 2004 PSG had paid over approximately £1.3 million to Kingswood.
114. Mr Gill seeks to explain this experience away as a mix-up by Syrius which was largely sorted out before Syrius became insolvent. He says that there were no features of this experience which should have made him suspicious about carrying on trading as he had before, because the problems were “entirely with Syrius”. Accordingly, he claims there was nothing to give rise to any suspicions on his part as to continued dealing with Kingswood.
115. We consider that a cautious and prudent businessman (as Mr Gill described himself) should have been suspicious at the repeated and easy opportunities offered to him, without any significant expertise or effort on his part, to generate apparently risk-free profits of 5% even when goods clearly went missing. The fact that Kingswood was offering him these opportunities out of the blue was too good to be true, and the fact that UKT also approached him out of the blue shortly after he started dealing with Kingswood should also have made him suspicious.
116. Mr Gill did accept in cross examination that on any view his experience in the September 2004 deal with UKT acted as a “wake up call” as to the importance of insurance as the goods were not insured in that deal and he had a real concern that if they did not arrive at UKT he would not get paid but still have to pay Kingswood.
(h) October 2005 deal with Euro Gulf Trading of Dubai – Safeguard Secure Viewer software
117. We had very little evidence about PSG’s dealings from September 2004 up to October 2005. On 27 October 2005, it bought 70,000 units of “Safeguard Secure Viewer” which Mr Gill described as “a software program to open documents where nobody else can view them”. It bought them from Kingswood and sold them on in two equal halves on 4 and 14 November 2005 to Euro Gulf Trading (“EGT”) in Dubai, at a mark-up of 5.16%. Mr Gill said this was not the first deal he had done with EGT, but he was not asked how he had first come to deal with them.
118. Mr Gill said that in October/November 2005, Kingswood were giving PSG about 30 days credit, and he was sure he never paid them more than 7 to 10 days late. He allowed EGT 30 days credit. In cross examination, he said he thought EGT had paid him within the 30 days he allowed them. The deal generated a VAT repayment claim of £6,639,500, which was paid by HMRC without significant delay and was received by PSG on 29 December 2005.
Money received from EGT |
Money paid on to Kingswood |
3 payments totalling £7.9 million |
£8 million in one payment |
3 payments totalling £8.5 million |
£9 million in one payment |
2 payments totalling £3.55 million |
£4 million in one payment |
2 payments totalling £5 million |
£5.3 million in one payment |
2 payments totalling £6 million |
£6.5 million in one payment |
£3 million in one payment |
£3.2 million in one payment |
2 payments totalling £5.95 million |
£8,579,500 in one payment |
Total received: £39.9 million |
Total paid: £44,579,500 |
122. Mr Gill was unclear and unconvincing in his answers to questions about how these payments came about. He could not remember whether he had chased EGT for payment after their 30 days were up, even though this was by far the largest deal he had done at that time and he would have been personally ruined if he had had to pay Kingswood without receiving payment from EGT. He was unclear about whether EGT had warned him the money was on its way, though he was expecting it in tranches rather than a single payment. He said Kingswood did chase him for payment, but he was not clear about what he told them. After some hesitation he said he had been checking his account (as he usually did, twice a day) and saw that some money had been received. He passed it on. He did not think to wait until he had received all the money that was due, nor did he question why it was being received in such a large number of comparatively small instalments. He denied that the payments had been prompted by the receipt of PSG’s VAT repayment, but we found his evidence in that regard wholly unconvincing.
123. Mr Gill did not allege he could have paid Kingswood without receiving the bulk of the funds first from EGT. On his evidence as to the credit terms between PSG and its two counterparties, he was due to pay Kingswood between 8 and 18 days before he could expect to receive the funds from EGT and yet he asserted there was no arrangement with Kingswood that he would only pay them when he received payment from EGT. Given that he described himself as “cautious” and “prudent” in business matters, we consider there must have either been such an arrangement (in which case he was at best misleading the Tribunal in his evidence) or he was showing a quite extraordinary lack of basic business sense in this, his largest deal to date. Having seen Mr Gill give evidence, we find that there was an understanding or arrangement with Kingswood that they would only be paid as and when PSG received payment from its customer EGT and its VAT repayment. The willingness of Kingswood to enter into such an arrangement should have aroused Mr Gill’s suspicions about the bona fides of Kingswood.
(i) January 2006 sale of further software to EGT
126. Although the evidence about this deal before us was sparse, there are a number of obvious points arising from this sequence of events which were not addressed during Mr Gill’s cross examination. The first is that on his own evidence, he was personally extending further credit of over £55 million to EGT at a time when they were already overdue in paying him some £30 million from the October 2005 deal referred to above (this deal took place at a time when the business was still being conducted by him as a sole trader with full personal liability). Second, Kingswood were affording him the same benefit (except that the amounts were larger, because of the additional VAT). There is no suggestion that the goods had been shipped “on hold”, and Mr Gill’s letter dated 20 March 2006 refers to the fact that the goods which had by then arrived in Dubai were already in the customer’s warehouse. PSG was therefore entirely dependent upon the customer and EGT to fulfil their promises, with no continued hold over the goods. Mr Gill gave no indication as to why he thought Kingswood should be so relaxed about the non-receipt of payment for their goods that had been shipped to Dubai out of their control, nor that he had even given the matter any thought.
(a) April deal – sale of Nokia telephones to 2Trade BVBA for £3,869,500 (input VAT claimed of £651,175)
130. This was PSG’s first deal in mobile phones. Mr Gill said in evidence that he had done some “limited general research” into that market sector over the two or three months leading up to this first trade. As a result, he decided to move into the sector (though it is not disputed he was well aware of the VAT fraud prevalent in that market sector). In his witness statement he said he found 2Trade as a possible customer as a result of finding them “on one of the trading websites” (though he could not remember which one). He said that he telephoned “Mrs de Volere” (the correct spelling is “Voldere”) of 2Trade, who introduced herself as the proprietor of 2Trade, and they subsequently exchanged details of their respective companies by faxed letters.
131. Officer Baines’ witness statement on the other hand was quite clear in saying that Mr Gill had told him on two occasions that the first approach had come from 2Trade, and officer Baines was not pressed on the point during his cross examination.
“ JB Customers?
SSG 2 Trade BV Europe. They contacted me.
JB Why?
SSG Think they looked at websites.
JB Do you know what IPT website it?
SSG Generally get people contact us, could be re CPUs, freight forwarder, can’t explain why other than get known in trade.”
“How and why did your customer come to contact you out of the blue? Have you any correspondence prior to this contact? Have you further auditable evidence of e-mail or telephone contact – I would think it not unreasonable to expect some degree of contact prior to entering into multi-million pound deals.”
“3. INTRODUCTIONS: Our client receives many letters of introduction, usually as a result of customers looking at their web site. Our client only deals with those customers following extensive due diligence which in this case comprised discussions with Mrs Hyacint de Voldere who is a director of 2Trade BVBA, and credit and tax checks which proved satisfactory.”
135. If Mr Gill had previously said that the approach to 2Trade had come from him and not them, this would have been a very obvious point to have picked up and corrected in TLS’s letter of 4 July 2006.
“197. How did contact come about? A. By phone – I got an unsolicited introduction and stock request from 2Trade – people in the trade know me – I get about 5 introductions a week but I do not record them”
“Got to meet 2Trade through an introduction and stock request – people in the trade know me, I don’t know how people get hold of my name – I may get 5 a week but I don’t keep copies.
Just an introduction – unsolicited.”
138. Having seen Mr Gill give evidence, we are satisfied that officer Baines’ record of what Mr Gill said at the meetings in May and August 2006 gives the truth. We therefore find as a fact that 2Trade did indeed approach PSG “out of the blue”. This is all the more suspicious because PSG had never traded in mobile phones before, so there would be no reason why someone involved in that market would think to approach them for stock.
139. In TLS’s letter dated 4 July 2006, it was said that Mr Gill had carried out “extensive due diligence” on 2Trade, in the form of:
“discussions with Mrs Hyacint de Voldere who is a director of 2Trade BVBA, and credit and tax checks which proved satisfactory. The foreign language documents provided comprise copies of the Belgian VAT/Tax Certificate and details of the company showing share capital, date of commencement, tax registration details and directors details. Our client confirmed the contents of these documents prior to trading.”
140. In fact, the due diligence carried out by Mr Gill on 2Trade before dealing with them consisted of:
(1) the receipt by fax on 25 April 2006 (timed at 17.48) of an introductory letter in English, in which 2Trade described itself as “worldwide traders in mobile phones and computer parts and have several years of experience in the industry.”
(2) Attached to this letter were two official looking documents, apparently in Flemish, totalling three pages. One of them appears to include an official looking stamp and a number that is clearly a Belgian VAT number. The other appears to be some kind of summary of constitutional information, but beyond the reference to Hyacint de Voldere’s name there is no obvious significance to any of the information in it. Mr Gill did not pretend to understand it.
(3) There was also some reference in the documentary evidence to the existence of some kind of check on 2Trade’s VAT number – possibly even a verification of it by HMRC’s Redhill office. We were not directed to (and could not find) a copy of such a document in the evidence, but we are prepared to assume for present purposes that such a check was made.
141. Mr Gill confirmed that he had not sought or taken up any references on 2Trade, or visited their business premises.
142. Mr Gill said he sent a copy of his own introduction documents to 2Trade, and at lunchtime on the following day (26 April 2006), Mr Gill received a fax from Ms de Voldere at 2Trade entitled “Stock Request”, as follows:
“Dear Mr Gill,
We are looking for the following stock CIF Netherlands.
Quantity Description
10,000 Nokia 8800
10,000 Nokia N90
5,000 Nokia 9300i
Please transmit us your best price cif.
Best regards”
143. Mr Gill said he contacted Kingswood in an attempt to source the stock. They told him they only had available smaller quantities of the phones requested, namely 5,000 Nokia 8800’s and 7,000 Nokia N90’s. Mr Gill discussed prices with Kingswood, offered a price to 2Trade (which was accepted without negotiation) and then agreed the deal with both parties. He agreed with 2Trade that they would insure the goods but he would pay for the shipping cost. He obtained no evidence from 2Trade that any insurance had been put in place, in spite of his previous experience when goods had gone astray and he might have ended up having to pay for them without being able to require payment from his customer.
145. 2Trade, in spite of being a Belgian company, required the phones to be shipped to a warehouse in the Netherlands. This did not concern Mr Gill. The goods were held on behalf of Kingswood at the warehouse of a company called Capital Logistics (GB) Limited (“Capital”) in Stoke on Trent. Kingswood released the phones to PSG unconditionally by an instruction to Capital on 26 April 2006 and they were transported by SKD Transport Limited of Oldbury to the Netherlands. The shipping document which accompanied the goods included the instruction “ship on hold”, though there was no reference to that instruction on the fax sent by PSG to Capital or in Capital’s records. Nor was there a copy of any written release note from PSG instructing the release of the consignment. PSG’s invoice stated “Terms: Strictly 30 Days Net” as well as “C&F”.
146. In his witness statement, Mr Gill said he had made no attempt to source from another supplier the remainder of the mobile phones requested by 2Trade. He said this was because he was “concerned about the cost”. Given the size of the deals he had completed with Kingswood over the previous six months, this seems a little odd. This point was not put to Mr Gill in cross examination, so we do not read too much into it, except to observe that it implies Mr Gill clearly had a very special relationship with Kingswood. This is borne out by the fact that the invoices from Kingswood contained no reference to payment terms, nor did the purchase order from PSG to Kingswood.
147. It is apparent from the statement of officer Mendes that Mr Gill received into his FCIB account on 9 May 2006 two sums totalling £3,869,500 (the exact net sale proceeds of PSG’s invoiced sale to 2Trade). Mr Gill paid this amount on to Kingswood’s FCIB account on the same day. In his statement, officer Mendes confirms there is no evidence in Mr Gill’s FCIB account of the outstanding balance of £502,674.50 ever being paid by him to Kingswood, and this is also apparent on the face of the FCIB statements included in the documents before us. Mr Gill was not expressly asked about this in his cross examination, but he gave no evidence to suggest he had in fact paid this outstanding amount through any other means, or that there had been any serious attempt by Kingswood to pursue it. We find this suspicious. Either there was an understanding between PSG and Kingswood that PSG would not be required to pay any more than it received, or Kingswood were simply not chasing up payment of very large amounts of money due to it. Either way, we find it very suspicious and consider that Mr Gill should have had the same reaction.
148. Mr Gill said he had carried out a Creditsafe check on 2Trade before dealing with them, but he was unable to produce any evidence to that effect and we find that he did not in fact do so. He admitted he had not met anyone from 2Trade or visited their premises or attempted to take up any trade or other references before dealing with them.
(b) 25 & 30 May 2006 deals – sale of Nokia and Sony Ericsson telephones to 2Trade BVBA for £5,456,975 (input VAT claimed of £918,111.25)
151. Payment followed a similar pattern as before. Mr Gill received payment into his FCIB account for three of the 25 May 2006 deals from 2Trade on 21 June 2006 (by way of three separate payments, which he aggregated and passed on to Kingswood in one payment, after making a small deduction whose purpose was unclear). He received payment for the other 25 May deal on 4 July 2006, by way of a single payment which he passed on with an extra amount which made up for the shortfall on the earlier payments apart from a few hundred pounds.
(c) May 2006 deal with Crestview and Fone Link
154. On Mr Gill’s own admission, both Crestview and Fone Link approached him, unsolicited, on 25 May 2006. He had given contradictory stories to HMRC as to whether Crestview or Fone Link approached him first, but it was within a matter of hours on 25 May.
“Dear Sir/Madam,
In reference to the purchase order that we have faxed to you (P.O. NUMBER 115) asking for 63,000 SLZ79 P4/630 INTEL PENTIUM CPU PROCESSORS, please deliver the goods to the following address:
Luxemburg Logistics S.A.R.L.
Unit 18, Rue Desjoncs L-18
18 Howald (Luxemburg)
We also need copy of inspection certificate.
Regards
T.H. Sarfraz”
“Hi
We have the following stock to offer in JSA Logistics:
UNITS: 63000 (200 BOXES) STOCK: CPU SL7Z9 PRICE: £80.00
Please advise if you are interested in the above.
Kind Regards,
Kevan Anderson”
161. Mr Gill said he had not noticed that the shipping instructions appeared to have been received from Fone Link before their introduction or any negotiations about an order. His explanation was that he worked in a fairly large building and often he was out of his office for a while, with correspondence being piled on his desk for him to consider on his return. We find that explanation wholly implausible. From this sequence of events alone, it should have been completely plain to Mr Gill that the only explanation for the Crestview/Fone Link deal was that it was connected to VAT fraud.
163. The pattern of payments made pursuant to this transaction is also suspicious. Mr Gill was not asked about the payment arrangements that had been negotiated with Crestview and Fone Link. No payment terms appear to have been mentioned in the negotiations with Crestview – certainly none appeared on their invoice.
164. PSG’s invoice to Fone Link included the endorsement “Terms: Strictly 30 Days Net”. The invoice was dated 1 June 2006, and payment should therefore have been made by 1 July 2006. In fact, payment was received by PSG in eight instalments of between £429,000 and £760,000 each over the period 24 July to 4 August 2006. Mr Gill did not mention any difficulties about obtaining payment, or any attempts by him to chase payment once it was overdue (or indeed any chasing by Crestview for payment). The total sum of £5,229,000 was received into PSG’s FCIB account and paid on to Crestview but there is no evidence that PSG ever paid the outstanding balance of £674,493.75 or was chased for that balance by Crestview. We consider that this would only have happened if there was some understanding in place at the time of the deal that PSG would only pay over what it received or if Mr Gill totally closed his eyes to the question of payment terms at that time. Either way, if Mr Gill was not actually aware of a connection to VAT fraud, we consider that he should have been.
166. It is true that PSG’s due diligence on 2Trade, Crestview and Fone Link was extremely sketchy, and much of it was carried out late. Personal visits to traders can reveal a certain amount about their business and we would expect any sensible businessman trading in such high values at least to visit the business premises of his customers and suppliers and personally meet the individuals managing them. Mr Gill did not do this. The discovery, for example, that one individual was supposedly running a multi-million pound import/export business on his own from his home might prompt a prudent businessman to question the substance and bona fides of the business. Beyond this sort of general impression, it is however difficult to say what extra useful knowledge PSG would have acquired from carrying out due diligence on its trading partners, including personal visits, trade and professional references and obtaining timely full financial information. As for due diligence on Kingswood, there is again something to be said for the proposition that after dealing with them exclusively for two apparently largely trouble-free years, there would have been very little to be gained by going through the exercise of gathering further information about them which would have been unlikely to uncover fraud.
173. The appeal is therefore dismissed.
Schedule 1 part 1 – Summary of deals giving rise to denied input VAT of PSG
Deal Period/Ref |
Purchase Date |
Products |
Purchase Price (ex VAT) |
Purchase VAT |
Sale Price (no VAT) |
Bought from |
Sold to |
Defaulter |
04/06 – 1 |
26 April 2006 |
3000 x Nokia N90 phones |
£789,000 |
£138,075 |
£820,500 |
Kingswood |
2Trade |
C&B |
04/06 – 2 |
26 April 2006 |
2500 x Nokia N90 phones |
£657,500 |
£115,062.50 |
£683,750 |
Kingswood |
2Trade |
C&B |
04/06 – 3 |
26 April 2006 |
1500 x Nokia N90 phones |
£394,500 |
£69,037.50 |
£410,250 |
Kingswood |
2Trade |
C&B |
04/06 – 4 |
26 April 2006 |
2200 x Nokia 8800 phones |
£827,200 |
£144,760 |
£860,200 |
Kingswood |
2Trade |
C&B |
04/06 – 5 |
26 April 2006 |
1500 x Nokia 8800 phones |
£564,000 |
£98,700 |
£586,500 |
Kingswood |
2Trade |
C&B |
04/06 – 6 |
26 April 2006 |
1300 x Nokia 8800 phones |
£488,800 |
£85,540 |
£508,300 |
Kingswood |
2Trade |
C&B |
|
|
|
|
|
|
|
|
|
05/06 – 1 |
30 May 2006 |
2400 x Nokia 8800 phones |
£825,600 |
£144,480 |
£858,600 |
Kingswood |
2Trade |
RS Sales |
05/06 – 2 |
30 May 2006 |
3000 x Nokia 9500 phones |
£849,000 |
£148,575 |
£882,750 |
Kingswood |
2Trade |
RS Sales |
05/06 – 3 |
30 May 2006 |
3500 x Sony Ericsson W810i phones |
£822,500 |
£143,937.50 |
£855,750 |
Kingswood |
2Trade |
RS Sales |
05/06 – 4 |
31 May 2006 |
63000 x Pentium P4 SL7ZP CPUs |
£5,024,250 |
£879,243.75 |
£5,229,000 |
Crestview |
Fone Link |
See Note 1 |
05/06 – 5 |
25 May 2006 |
2000 x Nokia 9300i phones |
£550,000 |
£96,250 |
£572,000 |
Kingswood |
2Trade |
RS Sales |
05/06 – 6 |
25 May 2006 |
2000 x Nokia 8800 phones |
£688,000 |
£120,400 |
£715,500 |
Kingswood |
2Trade |
RS Sales |
05/06 – 7 |
25 May 2006 |
3750 x Nokia N70 phones |
£686,250 |
£120,093.75 |
£714,375 |
Kingswood |
2Trade |
RS Sales |
05/06 – 8 |
25 May 2006 |
3000 x Nokia 9300i phones |
£825,000 |
£144,375 |
£858,000 |
Kingswood |
2Trade |
RS Sales |
Note 1: Through Crestview as contra trader, HMRC connect this purchase to fraudulent defaults by Red Rose, Zenith and West 1.
Note 2: PSG invoiced all 6 deals in 04/06 on one invoice and regarded them as a single deal.
Note 3: PSG invoiced deals 1-3 in 05/06 on one invoice and regarded them as a single deal.
Note 4: PSG invoiced deals 5-8 in 05/06 on one invoice and regarded them as a single deal.
|
|
|
|
|
Fone Link SL (Spain) 2Trade BVBA (Belgium) Crestview £5,024,250 + £879,243.75 VAT Kingswood
£2,196,750 + £384,431.25 VAT Kingswood
£1,674,000 + £292,950 VAT Kingswood
£1,375,600 + £240,730 VAT Kingswood
£1,221,700 + £213,797.50 VAT Kingswood
£2,499,300 + £437,377.50 VAT PSG
Proxy Partners (Belgium) Remotec (Spain – 1 deal) & Stankom (Germany – 4) Remotec (Spain - 2 deals) & Stankom (Germany - 1) PSG Network Euro Fine Peace (China) Ltd (Hong Kong ) Numerous UK Traders
Schedule 2
Explanation of contra trading
1. The essence of the concept of contra trading (which is HMRC’s own coinage) is that it comprises an extra step inserted into what might be called a “classic VAT fraud” in order to conceal that fraud and in order to make it harder for HMRC to recover the lost VAT if and when they do detect it.
2. A classic VAT fraud for these purposes arises when a UK trader acquires goods from another EU country, effectively free of VAT. He then supplies them to another UK trader, charging VAT. He then disappears with that VAT without paying it over to HMRC. That is where the actual fraud is perpetrated.
3. The goods are then supplied to another overseas customer without having to charge VAT (but reclaiming the VAT paid to the missing trader as input tax under the normal rules), either directly by the first purchaser from the missing trader or (more usually, in the interests of concealment) after a chain of supplies through other UK traders (all of whom will charge output VAT and suffer input VAT under the normal rules, usually each generating a very small profit and corresponding net output VAT liability).
4. Each of the UK traders will ensure that he receives the VAT on his onward sale in order to pay the VAT due to his own supplier. At some point, however, the goods must be sold overseas in order to generate the VAT repayment claim from HMRC which repays to the last UK trader in the chain the VAT which he has paid to his supplier.
5. In practice that last trader in the chain is the party mainly at risk in the whole structure, as HMRC can withhold his VAT repayment until they are satisfied that it is untainted by fraud.
6. As HMRC became more careful about investigating chains of transactions before releasing VAT repayments, the the concept of contra trading was developed as a counter measure. A trader with a potentially large (and therefore suspect and vulnerable) repayment claim (“Trader 1”) would enter into a separate transaction or series of transactions designed to substantially reduce or eliminate that repayment claim.
7. The means of doing so would be to acquire goods from an EU supplier (to an appropriate value) in a VAT free purchase and then generate an output VAT liability by selling them on to a UK trader (“Trader 2”) who would then sell the goods overseas again in a zero rated sale.
8. The repayment claim of Trader 1 (which could be traced back directly to fraudulent VAT defaults by traders who had supplied goods to him, directly or through other UK traders) would be reduced or cancelled out by his output tax liability to Trader 2, so HMRC would be less likely to investigate Trader 1’s dealings in detail and would not have the leverage of an outstanding VAT repayment claim while doing so; and if they investigated Trader 2’s large VAT repayment claim, they would find no fraudulent VAT default in the chain of UK purchases and sales of the goods leading up to Trader 2.
9. The chain of transactions leading from Trader 1 to Trader 2 (there may be other UK traders between them, all accounting properly for input and output VAT) is known by HMRC as the “clean chain”.
10. In contrast, the chain of transactions leading from the original fraudulent trader to Trader 1 (usually involving other UK traders, called “buffers” by HMRC, all accounting properly for input and output VAT) is known as the “dirty chain”.
11. The shifting of the VAT repayment claim by Trader 1 from the dirty chain to the clean chain means that effectively a “cut-out” has been inserted between the original fraud and the trader (Trader 2) which is ultimately claiming the repayment that actually crystallises the loss flowing from that fraud.
12. Trader 2 will assert that it neither had nor could have had knowledge of any fraud. This gives HMRC another hurdle to overcome if they try to recover their loss by refusing to satisfy the repayment claim of Trader 2, the ultimate dispatcher/exporter.
Schedule 3
Summary of VAT returns from 1.1.99 to 31.5.06
VAT Period |
Outputs |
Inputs |
Net VAT |
EC Supplies |
EC Acquns |
03/99 |
0 |
26,113 |
-13,367 |
0 |
0 |
06/99 |
118,163 |
119,310 |
-10,178 |
0 |
0 |
09/99 |
142,095 |
45,380 |
-1,197 |
0 |
0 |
12/99 |
171,577 |
112,244 |
-4,588 |
0 |
0 |
03/00 |
119,711 |
76,290 |
1,696 |
0 |
0 |
06/00 |
60,977 |
71,122 |
-1,058 |
0 |
0 |
09/00 |
114,178 |
85,631 |
-2,434 |
0 |
0 |
12/00 |
259,090 |
415,240 |
-26,596 |
0 |
0 |
03/01 |
179,421 |
55,184 |
11,667 |
0 |
0 |
06/01 |
84,620 |
39,400 |
2,922 |
0 |
0 |
09/01 |
159,879 |
57,317 |
15,057 |
0 |
0 |
12/01 |
203,425 |
187,125 |
-13,246 |
0 |
0 |
03/02 |
27,795 |
70,903 |
-8,229 |
0 |
0 |
06/02 |
77,210 |
38,370 |
2,973 |
0 |
0 |
09/02 |
156,335 |
32,638 |
7,107 |
70,851 |
0 |
12/02 |
60,267 |
64,150 |
-3,040 |
8,602 |
0 |
03/03 |
349,348 |
353,136 |
-53,265 |
0 |
21,675 |
06/03 |
28,187 |
38,168 |
2,483 |
0 |
9,009 |
09/03 |
299,327 |
273,628 |
-39,235 |
0 |
8,505 |
12/03 |
606,481 |
555,666 |
-84,978 |
525,041 |
17,612 |
01/04 |
498,523 |
505,950 |
-83,051 |
0 |
8,946 |
02/04 |
1,864 |
5,781 |
-600 |
0 |
0 |
03/04 |
996,208 |
926,292 |
-157,782 |
0 |
0 |
04/04 |
1,682,100 |
1,627,221 |
-281,164 |
0 |
14,092 |
05/04 |
2,406,804 |
2,339,494 |
-401,492 |
0 |
37,367 |
06/04 |
6,234 |
32,057 |
-962 |
0 |
19,903 |
07/04 |
10,595 |
13,270 |
-395.69 |
0 |
0 |
08/04 |
26,223 |
17,367 |
1,708 |
0 |
0 |
09/04 |
2,578,374 |
2,440,544 |
-422,485 |
0 |
0 |
10/04 |
36,276 |
13,402 |
2,346 |
0 |
0 |
11/04 |
1,186,680 |
1,763,535 |
-305,146 |
0 |
14,810 |
12/04 |
1,616,489 |
920,803 |
-157,859 |
960,000 |
0 |
01/05 |
14,855 |
38,567 |
-602 |
0 |
16,491 |
02/05 |
1,567,121 |
1,524,020 |
-260,659 |
1,015,000 |
23,468 |
03/05 |
7,904 |
29,663 |
-830 |
0 |
16,673 |
04/05 |
1,520 |
43,284 |
-1,201 |
0 |
24,159 |
05/05 |
0 |
3,970,155 |
-690,303 |
0 |
23,160 |
06/05 |
4,146,620 |
4,569,121 |
-794,566 |
0 |
1,789 |
07/05 |
4,806,731 |
9,508,514 |
-1,661,460 |
0 |
0 |
08/05 |
9,987,906 |
12,912,539 |
-2,253,094 |
0 |
2,532 |
09/05 |
13,645,842 |
16,647,678 |
-2,894,094 |
0 |
0 |
10/05 |
1,747,341 |
37,970,907 |
-6,639,530 |
0 |
0 |
11/05 |
39,881,676 |
103,699 |
-11,561 |
0 |
0 |
12/05 |
7,090 |
7,435 |
300.68 |
0 |
0 |
01/06 |
59,850,653 |
56,973,559 |
-9,968,202 |
0 |
0 |
02/06 |
851 |
90,435 |
-5,846 |
0 |
0 |
03/06 |
59,678,434 |
76,793,323 |
9,957,387 |
0 |
0 |
04/06 |
3,871,051 |
3,731,000 |
-652,653 |
0 |
0 |
05/06 |
5,457,808 |
10,309,224 |
-1,801,881 |
5,456,975 |
0 |