In this month’s review, Gary Barnett and Bryn Reynolds (Simmons & Simmons) consider the impact of recent case decisions on input VAT for a fundraising transaction, the meaning of appealable decision and HMRC’s approach to evidence of export.
VAT groups acquisitions and fund raising
In Ince Gordon Dadds LLP v HMRC [2023] UKFTT 4 the FTT held that input VAT incurred by a holding company on a combined reverse takeover and fundraising transaction was not recoverable as input VAT. Although the FTT accepted that input VAT incurred by a holding company might properly be attributed to the downstream activities of the VAT group of its target on the basis of its intention to join that VAT group the input VAT in this particular case did not qualify. To the extent that the input VAT was incurred to raise extra finance the use of those funds to...
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In this month’s review, Gary Barnett and Bryn Reynolds (Simmons & Simmons) consider the impact of recent case decisions on input VAT for a fundraising transaction, the meaning of appealable decision and HMRC’s approach to evidence of export.
VAT groups acquisitions and fund raising
In Ince Gordon Dadds LLP v HMRC [2023] UKFTT 4 the FTT held that input VAT incurred by a holding company on a combined reverse takeover and fundraising transaction was not recoverable as input VAT. Although the FTT accepted that input VAT incurred by a holding company might properly be attributed to the downstream activities of the VAT group of its target on the basis of its intention to join that VAT group the input VAT in this particular case did not qualify. To the extent that the input VAT was incurred to raise extra finance the use of those funds to...
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