The total value of identifiable VAT reclaims made or intended to be made, and the total amount actually paid out by way of VAT reclaim, would in most cases provide the most reliable starting point for sentencing in missing-trader fraud cases.
CA (Crim Div) (Hooper LJ, Holroyde J, Supperstone J) 18/1/2012
[2012] EWCA Crim 1