HMRC’s VAT appeal update has confirmed that this case will be heard in June 2025. For background, the taxpayer was a holding company and decided to dispose of a 100% owned subsidiary by way of an exempt share sale to finance the development of a new hotel that would generate taxable income. The original FTT supported the taxpayer’s argument that there was a direct and immediate link between the VAT on the professional fees and the downstream taxable services and the VAT was not a cost component of the exempt supply. HMRC’s appeal was dismissed at the UT but the decision was overturned at the CoA. To access the earlier CoA judgment, click here.
Source KPMG
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