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       #Post#: 35716--------------------------------------------------
       Re: VCS - Bristol Airport - PCN for 'Stopping to Pick up/Drop
       off a passenger' at a temporary red light
   DIR By: DWMB2
       Date: September 5, 2024, 5:08 am
       ---------------------------------------------------------
       Your question #1 was about the debt collection fees, not whether
       the original parking charge is subject to VAT. They haven't even
       bothered to answer #2. For #3, you have only uploaded 3 pages
       (of what should be 8, by the looks of the footers), is that
       because they only sent you 3?
       That contract had also expired at the time the parking charge
       notice was issued.
       #Post#: 35717--------------------------------------------------
       Re: VCS - Bristol Airport - PCN for 'Stopping to Pick up/Drop
       off a passenger' at a temporary red light
   DIR By: BDayOwl
       Date: September 5, 2024, 5:11 am
       ---------------------------------------------------------
       Yes, this is everything they sent me.
       At this point do I go back questioning those points?
       #Post#: 35720--------------------------------------------------
       Re: VCS - Bristol Airport - PCN for 'Stopping to Pick up/Drop
       off a passenger' at a temporary red light
   DIR By: BDayOwl
       Date: September 5, 2024, 5:18 am
       ---------------------------------------------------------
       I also note that they've alluded to the BPA's code of practice,
       but VCS aren't a BPA Approved Operator. Is this anything?
       #Post#: 35726--------------------------------------------------
       Re: VCS - Bristol Airport - PCN for 'Stopping to Pick up/Drop
       off a passenger' at a temporary red light
   DIR By: b789
       Date: September 5, 2024, 5:50 am
       ---------------------------------------------------------
       Is what you’ve shown us, the sum total of the “contract” they
       have sent to you?
       Regarding the “template” response to the other questions
       asked...
       --- Quote ---
       > This is not our client’s usual business, and the resources
       could have been better spent in other areas of the business. Had
       you of paid as per the Contract, there would have been no need
       for recovery action so the amount due would not have increased.
       --- End Quote ---
       Just to highlight the level of intellectual malnourishment you
       are dealing with here, you can tell by the highlighted bit above
       that you are dealing with people who apparently never finished
       basic English grammar in primary school.
       The response to the three questions is evasive and incomplete,
       providing limited answers and not addressing all your concerns
       directly. You asked whether the £70 charge is a debt recovery
       fee and if it's inclusive or exclusive of VAT, specifically why
       you'd be covering the operator’s VAT liability.
       They cite the HMRC guidance, asserting that parking charges fall
       outside the scope of VAT, so no VAT invoice is needed. They have
       not directly clarified whether the £70 includes VAT or addressed
       the concern about VAT liability being passed to you. They have
       avoided explaining the exact composition of the £70 fee in terms
       of VAT and have tried to justify it as a debt recovery fee based
       on internal costs.
       The second question asked whether the principal sum was being
       claimed as damages or as consideration for a service. In their
       response, they don’t explicitly answer whether it's damages or
       consideration, but they imply the amount reflects what you would
       have (of) paid under the contract (for parking). They emphasise
       that the fee increased due to non-payment and recovery efforts.
       The nature of the principal sum remains vague as they focus on
       the rationale for additional fees rather than clarifying the
       legal basis of the charge itself (damages vs. consideration).
       The third question requested evidence of a valid contract
       involving the landowner, OTPP, and their managing agent, Bristol
       Airport Ltd, granting their client the right to issue PCNs. The
       excuse for a contract provided, consists of only three pages
       (cover page, definitions/services, and a partial signature
       page).
       Crucially, the contract appears to be between Bristol Airport
       Ltd and the agent, VCS, not the landowner, as specifically
       requested. They have provided a partial contract that does not
       fully meet the request, as it lacks clear evidence of direct
       authorisation flowing from the landowner (OTPP) through the
       agent to VCS. The documentation is minimal and incomplete.
       Their response is evasive and focuses on justifying the charges
       rather than addressing the specific legal queries. The VAT issue
       is not fully explained, the legal nature of the principal sum is
       unclear and the excuse for a contract provided does not
       sufficiently prove the authority they claim to have from the
       landowner.
       DCB Legal are issuing thousands of claims every week and there
       appears to be a significant financial incentive to obscure the
       VAT aspect, particularly since they’ve chosen to sidestep the
       clear question regarding whether the £70 fee includes VAT. By
       failing to clarify whether the £70 is inclusive of VAT, they
       have avoided having to account for VAT payments to HMRC. This
       allows them to pocket the full amount, effectively overcharging
       you.
       As the fee should include VAT but they are not declaring it,
       this amounts to VAT fraud as they are collecting VAT from
       consumers without passing it on to the tax authorities. Debt
       recovery fees are supposed to reflect actual costs, but by
       inflating the figure and leaving the VAT question ambiguous,
       they anre unjustly enriching themselves under the guise of "cost
       recovery."
       As we strongly suspect VAT fraud, you should report the matter
       to HMRC, which may investigate whether the company is correctly
       accounting for VAT on these additional fees. It takes a few
       minutes to do so online here:
  HTML https://www.gov.uk/report-tax-fraud
       It’s very straightforward and once reported, you will have no
       further involvement. The sums involved are suspected to be in
       the “millions”.
       #Post#: 35729--------------------------------------------------
       Re: VCS - Bristol Airport - PCN for 'Stopping to Pick up/Drop
       off a passenger' at a temporary red light
   DIR By: BDayOwl
       Date: September 5, 2024, 5:52 am
       ---------------------------------------------------------
       Thanks for the above.
       Yes, just to be clear, the 3 pages I've shared is the sum of
       what was sent to me by DCBLegal.
       Very good point on the VAT front. I'll report them immediately.
       #Post#: 35733--------------------------------------------------
       Re: VCS - Bristol Airport - PCN for 'Stopping to Pick up/Drop
       off a passenger' at a temporary red light
   DIR By: b789
       Date: September 5, 2024, 6:00 am
       ---------------------------------------------------------
       We don’t normally recommend responding to their response to your
       response to the LoC but I’m minded to suggest something, just to
       give them notice that even though they are going to discontinue
       the claim in due course, they are on notice that their failure
       to comply with the PAP by not providing the answers or the full
       contract, is going to cause them anxiety as they scramble to
       cover their backsides.
       #Post#: 35747--------------------------------------------------
       Re: VCS - Bristol Airport - PCN for 'Stopping to Pick up/Drop
       off a passenger' at a temporary red light
   DIR By: DWMB2
       Date: September 5, 2024, 6:38 am
       ---------------------------------------------------------
       I'm broadly of the same view as b789... In general it's not
       worth getting into protracted correspondence at this stage.
       They're not going to budge from their position that you owe
       their client money and you're not going to budge from your
       position that you do not.
       But in this case, they haven't even bothered to answer one of
       your questions, and have done a shoddy job of answering the
       other two. Given that, pointing this out seems a decent movie.
       I'd be minded to ignore the contract date at this stage. If they
       want to present a contract that expired in 2023 as evidence they
       had authority to issue parking charges in 2024, let them crack
       on.
       #Post#: 35770--------------------------------------------------
       Re: VCS - Bristol Airport - PCN for 'Stopping to Pick up/Drop
       off a passenger' at a temporary red light
   DIR By: b789
       Date: September 5, 2024, 8:30 am
       ---------------------------------------------------------
       It is probably worth responding to them with the following:
       --- Quote ---
       > Subject: Mendacious Response and Failure to Comply with PAP
       >
       > Dear Shahera Begum,
       >
       > I write to address the glaring contradictions in your recent
       response and your apparent disregard for honesty and
       transparency.
       >
       > You have stated that parking charge notices fall outside the
       scope of VAT according to HMRC’s VATSC06140, and therefore, no
       VAT invoice is required. However, you go on to state that the
       additional £70 is for "debt recovery fees" incurred by your
       client as a result of my alleged non-payment.
       >
       > This assertion is inconsistent and misleading. Debt recovery
       fees, unlike parking charges, are not VAT-exempt. You have
       explicitly admitted that the £70 is for debt recovery, which is
       a separate service from the PCN. As such, these charges are
       subject to VAT. Yet, you have chosen to obscure this fact by
       refusing to provide a breakdown of the amount or clarify whether
       VAT has been included. This evasiveness strongly suggests that
       you and/or your client are knowingly attempting to recover an
       inflated sum without properly accounting for VAT.
       >
       > Furthermore, your reliance on the BPA Code of Practice to
       justify the £70 fee does not negate the fact that debt recovery
       services are not VAT exempt. Your failure to disclose whether
       VAT is included in this fee, combined with your attempt to
       characterise the £70 as part of a debt recovery process, exposes
       a deliberate effort to mislead.
       >
       > Should this matter proceeds to court, I will bring to the
       court's attention your blatant contradictions, your mendacious
       response, and your refusal to comply with the Pre-Action
       Protocol. This lack of honesty and transparency will be noted as
       an attempt to confuse and overcharge. The court is unlikely to
       look favourably upon such conduct, especially when coupled with
       your disregard for the rules governing pre-litigation
       disclosure.
       >
       > I strongly suggest you reconsider your position and provide
       the clarity and full documentation required by the PAP,
       including a proper breakdown of the £70 fee with reference to
       VAT. If you fail to do so, I will have no hesitation in using
       your own admissions against you and your client in any
       subsequent proceedings.
       >
       > Yours sincerely,
       >
       > [Your Name]
       --- End Quote ---
       Keep the failure to disclose the contract and the fact that they
       have failed to evidence the contract for subsequent comms. Let's
       see if they bother to respond to the above.
       It is a fact that any claim issued by DCB Legal will be
       discontinued just before they are required to pay the trial fee.
       The above is simply to have a bit of fun at their expense and
       puts them on notice that they are not dealing with low-hanging
       fruit on the gullible tree.
       #Post#: 35776--------------------------------------------------
       Re: VCS - Bristol Airport - PCN for 'Stopping to Pick up/Drop
       off a passenger' at a temporary red light
   DIR By: BDayOwl
       Date: September 5, 2024, 8:50 am
       ---------------------------------------------------------
       Appreciate the help! I've already sent a response but it
       effectively covers all of the points in your message.
       Thanks again.
       #Post#: 35780--------------------------------------------------
       Re: VCS - Bristol Airport - PCN for 'Stopping to Pick up/Drop
       off a passenger' at a temporary red light
   DIR By: b789
       Date: September 5, 2024, 9:02 am
       ---------------------------------------------------------
       It would help if you could show us any planned response, just in
       case there is anything that could prejudice your case that you
       may not have noticed but maybe we will.
       Can you please show us the wording you used in your response?
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