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MZ De Ferranti v HMRC

Expenditure by owner of Scottish estate

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...

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