Giles Salmond (Eversheds) provides his perspective on PPG and recent decisions of the CJEU, and looks at where this leaves us
Initially many saw the decision of the CJEU in Fiscale Eenheid PPG Holdings BV cs te Hoogezand (C-26/12) [2014] STC 175 as heralding a much improved position for the recovery of VAT on pension fund costs. However in this article I will explore how in my view the position is far from straightforward.
It is worth remembering that in the world before PPG life was relatively simple. In practice HMRC took a fairly relaxed attitude to the recovery of VAT on pension funds. The basic rule was that HMRC accepted that the costs connected with the setting up and day to day...
