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General Motors UK Ltd v HMRC

Valuation of self-supply

In General Motors UK Ltd v HMRC (TC02835 – 29 August) a major car manufacturer (G) had accounted for VAT on the basis that when it took into its own use a car which it had manufactured or imported it had made a deemed self-supply and VAT was chargeable on two-thirds of the retail list price of each car. Subsequently it submitted a substantial repayment claim on the basis that it should have accounted for VAT on a lower amount. HMRC rejected the claim and G appealed. The First-tier Tribunal reviewed the evidence in detail and allowed G’s appeal in principle. Judge Hellier held that for the period from 1987 to 1993 the value of the self-supply should be calculated as the lower of the purchase price of the cars and the cost of their cars. For the period from 1994 to...

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