- Disposal of shares for VAT purposes
- Original news
- What was the CJEU’s decision?
- The case related to a 30% shareholding. Would a case relating to a 100% shareholding have a different result?
- Is the ‘cost component’ approach to allocating input VAT settled law?
- Does the decision impact on HMRC’s guidance issued after Kretztechnik AG v Finanzamt Linz: C-465/03  STC 1118?
- What are the implications for lawyers and their clients? What should they do next?
- How does this decision fit in with other developments in this area?
Tax analysis: A recent Court of Justice of the European Union (CJEU) ruling on whether, for VAT purposes, a disposal of shares was equivalent to a transfer of a totality of assets leaves this area of law still horribly difficult, says barrister Roger Thomas, of Pump Court Tax Chambers.
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