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Abbeyford Caravan Company (Scotland) Ltd v HMRC

More favourable method of output tax apportionment applied retrospectively

In Abbeyford Caravan Company (Scotland) Ltd v HMRC [2024] UKFTT 928 (TC) (17 October) the FTT allowed the taxpayer’s appeal against a decision by HMRC that it could not apply a more favourable method of output tax apportionment retrospectively. It reached that decision after finding that the difference between the old method and the new method was substantial.

The taxpayer bought and sold caravans with removable contents charging a single price for each caravan and its contents. Subject to conditions the sale of a caravan may qualify for the reduced rate of VAT under VATA 1994 Sch 7A Group 12 or the zero rate of VAT under VATA 1994 Sch 8 Group 9. Both Sch 7A Group 12 and Sch 8 Group 9 include an exclusion for removable contents sold with caravans. The effect of the legislation is that...

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