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Goodrich Corporation v HMRC

Zero rating of military supplies

In Goodrich Corporation v HMRC [2014] UKFTT 1029 – 11 November 2014 the FTT found that the provision of military equipment was not zero rated.

The issue was whether supplies of military equipment to the US government for onward sale to the governments of Poland and Greece were zero rated under VATA 1994 Sch 8 Group 13 item 2. This in turn depended on whether the arrangements under which the sales were made amounted to ‘international collaboration arrangements’.

Under the Foreign Military Sales programme (which has the stated purpose of supporting US foreign policy and national security objectives) the US government can enter into formal contracts with other governments for the sale of military hardware which it can source from its own suppliers for onward sale.

The FTT observed that to fall within the zero rating exemption the arrangement...

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