The First-tier Tribunal (FTT) in Shop Direct decided that: VAT repayments restoring amounts which would have been brought in as trading receipts had the character of trading receipts; corresponding interest payments had the quality of interest or were assimilated to interest; and a succession of trade transfers over time did not prevent the VAT repayments being taxed as post-cessation receipts. However, the missing underlying analysis of the agents commission repayments and standard method of calculating gross takings may cast doubt over the authoritative status of the FTT’s decision.
