Hotel La Tour, Impact Contracting Solutions and a CJEU decision on deducting overpaid VAT are in this month’s review by Jo Crookshank and Gary Barnett (Simmons & Simmons).
Input VAT and share sales to raise funds
The decision of the Upper Tribunal (UT) in HMRC v Hotel La Tour Ltd [2023] UKUT 178 is an important confirmation that input VAT on costs associated with the exempt sale of shares made for the purposes of raising funds for the broader taxable business may be deductible provided that such costs do not form a cost component of the exempt sale. And on this latter point the UT has suggested that a strict interpretation of what amounts to a ‘cost component’ should be adopted.
Hotel La Tour Ltd (HLT) wholly owned a subsidiary HLTB with which it formed a VAT group. HLTB owned and operated a hotel and...
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Hotel La Tour, Impact Contracting Solutions and a CJEU decision on deducting overpaid VAT are in this month’s review by Jo Crookshank and Gary Barnett (Simmons & Simmons).
Input VAT and share sales to raise funds
The decision of the Upper Tribunal (UT) in HMRC v Hotel La Tour Ltd [2023] UKUT 178 is an important confirmation that input VAT on costs associated with the exempt sale of shares made for the purposes of raising funds for the broader taxable business may be deductible provided that such costs do not form a cost component of the exempt sale. And on this latter point the UT has suggested that a strict interpretation of what amounts to a ‘cost component’ should be adopted.
Hotel La Tour Ltd (HLT) wholly owned a subsidiary HLTB with which it formed a VAT group. HLTB owned and operated a hotel and...
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