Chris Bates and Julia Lloyd analyse the recent First-tier Tribunal decision in TLLC, part of a VAT group including the Travelodge hotel chain business, and the implications of the decision.
In the case of TLLC Ltd v HMRC [2013] UKFTT 467 (TC) the First-tier Tribunal has found that a disposal of shares in companies which carried on a property rental business was an economic activity and could not be considered to be a transfer of a business as a going concern. The disposal was therefore an exempt supply and the input tax incurred on professional fees in relation to the share disposal was irrecoverable.
At a policy level it is anomalous that if an integrated group carrying...
