- telent Technology Services placed funds in escrow for pension scheme and recovered input tax on fees for investment advice
- HMRC issued assessment to recover input tax, telent appealed but later withdrew
- telent renewed argument for input tax recovery, made claim for different period
- HMRC conceded input tax recovery but argued new claim could not overlap with previous period
- Upper Tribunal upheld decision that telent was prevented from re-litigating overlap period
- HMRC not barred from raising procedural issue of overlap period
- telent not able to re-litigate issue of input tax for overlap period
- Upper Tribunal dismissed telent’s appeal
Source: taxscape.deloitte.com
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.
