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VAT Recovery on Share Sale Costs: CoA Ruling and Implications for Taxpayers

  • Hotel La Tour sold shares to fund construction of a new hotel
  • HLT claimed VAT recovery on legal and PR costs associated with share sale
  • FTT and UTT agreed with HLT’s claim, but CoA ruled in favor of HMRC
  • CoA decided costs were directly attributable to VAT exempt share sale
  • Vendors should factor in irrecoverable VAT in share sale transactions
  • Some pre-transaction due diligence costs may be recoverable at HMRC’s discretion
  • Key takeaways: consider structuring arrangements differently for VAT recovery on costs

Source: claritastax.co.uk

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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