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Beauty Angels v HMRC

Deemed supply between associated companies

In Beauty Angels v HMRC [2015] UKFTT 641 (9 December 2015) the FTT found that no transfer of goods had taken place between associated companies but that one company had made supplies of services to the other.

The issue was whether Beauty Angels a company carrying on a beauty salon business had made a deemed supply of the goods used in the business for deemed consideration when another company (BASL) which was not registered for VAT and which belonged to the same shareholders had started carrying on the business whilst Beauty Angels had ceased to do so.

The FTT noted that VATA 1994 Sch 4 para 5(1) provides that ‘where goods forming part of the assets of a business are transferred … so as no longer to form part of those assets whether or not for a consideration...

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