VATF53415 - The Kittel principle intervention: Kittel in more detail: What is meant by 鈥榢new or should have known鈥�: Actual knowledge
Rarely will direct and explicit evidence be available that the taxable person knew he was involved in a transaction connected with fraudulent evasion of VAT. However, actual knowledge may be inferred from a range of circumstantial evidence about the way in which the transactions have taken place that the taxable person 鈥榤ust have known鈥� that his transactions were 鈥榗onnected with fraudulent evasion of VAT鈥�.