VATF52400 | The Kittel principle intervention: Overview: When and where to apply the Kittel principle

From HM Revenue & Customs · VAT Fraud

You can consider applying the Kittel principle to any claim for input tax irrespective of:

the type of transaction being undertaken (e.g. whether they are goods or services or what those goods or services are);
where in the transaction chain the taxable person is (e.g. whether they feature as a broker, buffer, contra etc (VATF23500));
whether the VAT return is a net payment to or repayment from HMRC; or
where the fraudulent evasion of VAT occurred (VATF53110 and VATF53115).