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MZ De Ferranti v HMRC

In MZ De Ferranti v HMRC (TC01288 – 25 July) a company director (F) had acquired a large estate in a remote part of the Scottish highlands which was inaccessible by road (and only accessible by boat from a large loch).

The previous owner had been registered for VAT and the transfer (which took place in 1993) had been treated as the transfer of a going concern.

Because of its remote location the Post Office did not deliver mail to the estate and paid F to deliver mail which he usually collected twice per week from the nearest town post office.

F reclaimed input tax on expenses relating to the distribution of the mail and also reclaimed input tax on expenses relating to the sale of venison from deer carcasses.

In 2008 HMRC...

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