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The Queen’s Club v HMRC

Input tax recovery and partially exempt traders

In The Queen’s Club v HMRC [2017] UKFTT 700 (22 September 2017) the FTT found that input tax incurred in relation to refurbishment works was fully recoverable.

The Queen’s Club made exempt supplies of sporting services and taxable supplies mainly of food and drinks. It had incurred costs refurbishing its restaurant facilities. The issue was the extent to which it was entitled to recover input tax on these costs. HMRC contended that there was a sufficient direct and immediate link between the renovation costs and exempt supplies of membership and of room hire for input tax to be irrecoverable. The tribunal rejected that submission finding that when the club made its restaurant available to members it did so as part of a catering service which was standard rated.

The question was therefore whether the club had established a sufficient...

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