V3.464A Attribution of specific transactions
Legislation and case law requires that input tax incurred on particular classes of transaction is attributable to those transactions in specific ways, which are detailed below.
Attribution for self supplies
Where persons make supplies to themselves under, or by virtue of, any provision of VATA 1994, the input tax on that supply is not allowable as attributable to that self-supply1. It must be attributed to the use to which that supply is actually put.
Attribution for securities and secondary securities
Under UK legislation, a body corporate may make either an exempt or a 'taxable' supply (strictly speaking, the supply is either exempt or made outside the UK and therefore outside the scope of UK VAT; in the latter case, however, related input tax is treated as attributable to taxable supplies2) if it makes an issue of shares or sells shares in one of its subsidiaries. Legal and accounting fees, underwriting commissions, London Stock Exchange listing fees, etc relating to the issue or disposal are properly attributable to the supply made3. See also Trinity Mirror plc4, where the appellant tried unsuccessfully to argue that a share issue was not a supply of services since it did not involve the transfer or depletion of resources, but was akin to the raising of money by the taking of a loan.
It follows that where the issue/sale is exempt, input tax on such costs will not be recoverable; where it is 'taxable', related input tax will be recoverable5.
However, the kind of
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