In Hotel La Tour Ltdv HMRC [2023] UKUT 178 (TCC) (24 July) the Upper Tribunal (UT) dismissed HMRC’s appeal and upheld the First-tier Tribunal (FTT) decision that a company was entitled to recover VAT on the cost of professional services incurred in relation to the sale of shares in its subsidiary. This was because it found there was a direct link between the share sale and onward taxable supplies.
Hotel La Tour Ltd (HTL) was the 100% owner of a subsidiary and provided management services to it. Both companies were members of the same VAT group. The subsidiary owned a hotel in Birmingham which HLT decided to sell to fund the development of a new hotel in Milton Keynes. This was achieved through the share sale of the subsidiary.
HLT sought recovery of the VAT incurred...
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In Hotel La Tour Ltdv HMRC [2023] UKUT 178 (TCC) (24 July) the Upper Tribunal (UT) dismissed HMRC’s appeal and upheld the First-tier Tribunal (FTT) decision that a company was entitled to recover VAT on the cost of professional services incurred in relation to the sale of shares in its subsidiary. This was because it found there was a direct link between the share sale and onward taxable supplies.
Hotel La Tour Ltd (HTL) was the 100% owner of a subsidiary and provided management services to it. Both companies were members of the same VAT group. The subsidiary owned a hotel in Birmingham which HLT decided to sell to fund the development of a new hotel in Milton Keynes. This was achieved through the share sale of the subsidiary.
HLT sought recovery of the VAT incurred...
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