Commentary

V7.189B Disaggregation—legislation and key rules

Part V7 Tax planning
Part V7 Tax planning | Commentary

V7.189B Disaggregation—legislation and key rules

Part V7 Tax planning | Commentary

V7.189B Disaggregation—legislation and key rules

The power of HMRC to deal with artificial business separations is contained in VATA 1994, Sch 1, para 1A, sub-paras (1) and (2) of which say:

“1A

(1)     Paragraph 2 below is for the purpose of preventing the maintenance or creation of any artificial separation of business activities carried on by two or more persons from resulting in an avoidance of VAT.

(2)     In determining for the purpose of sub-paragraph (1) above whether any separation of business activities is artificial, regard shall be had to the extent to which the different persons carrying on those activities are closely

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