Commentary

RCB/32/14 VAT—policy on holding companies

Part V16 Forms and other HMRC material

RCB/32/14 VAT—policy on holding companies

RCB/32/14 VAT—policy on holding companies

Revenue & Customs Brief, Issue 32. 24 September 2014

Purpose of this brief

This Revenue and Customs brief confirms that HM Revenue and Customs (HMRC) has reviewed its policy following the decision of the Court of Appeal in the case of British Airport Authority (BAA) ([2013] EWCA Civ 112). The decision confirms that VAT is only recoverable where there is a direct and immediate link to taxable supplies. BAA was refused permission to appeal to the Supreme Court. For the purpose of this brief, “taxable supplies” includes supplies not charged to UK VAT, but which carry a right to input tax recovery.

Following this decision there is no change in HMRC's policy. However the facts in BAA related to particular circumstances and the decision does not address other commonly encountered issues relating to holding

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