BB/23C/02 VAT—attribution of input tax incurred on professional services when a company acquires shares in another company in exchange for shares in itselfBusiness Brief, Issue 23. 20 August 2002BackgroundThis Business Brief article sets out Custom's policy following the decision of 24 June of the VAT and Duties Tribunal in the Southampton Leisure (LON/99/0466) appeal.The appeal was concerned with the attribution of input tax incurred on certain professional services by the business, when it issued shares to the shareholders of Southampton Football Club Limited in exchange for their shares. Customs' view was that the services were used exclusively for the purposes of an exempt issue of shares, whereas the taxpayer's view was that the services were used in making both taxable and exempt supplies.Tribunal's decisionThe tribunal partly allowed the appeal. Whilst it supported Customs' view that the services relating to the public
Business Brief, Issue 23. 20 August 2002
This Business Brief article sets out Custom's policy following the decision of 24 June of the VAT and Duties Tribunal in the Southampton Leisure (LON/99/0466) appeal.
The appeal was concerned with the attribution of input tax incurred on certain professional services by the business, when it issued shares to the shareholders of Southampton Football Club Limited in exchange for their shares. Customs' view was that the services were used exclusively for the purposes of an exempt issue of shares, whereas the taxpayer's view was that the services were used in making both taxable and exempt supplies.
The tribunal partly allowed the appeal. Whilst it supported Customs' view that the services relating to the public
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