Peter Jenkins considers the development of a new threat to input tax recovery by partly exempt businesses receiving subsidies
A paper submitted by Bruno Giordan of HMRC’s partial exemption policy branch dated 30 May 2014 on partial exemption and deduction of input tax to the annual VAT Practitioners’ Group conference on 11 and 12 June 2014 caused something of a stir. By all accounts it provoked a lively discussion following his talk. It was seen by many practitioners as presaging a new (but still developing) strand of thinking in HMRC’s partial exemption policy branch. This seeks in effect to link the right of deduction of input tax attributable to taxable activities to cases where the expenditure can be shown to be ‘incorporated into the price’ of the output transactions.
This...
