Commentary

V7.189F Disaggregation—effect of a direction issued by HMRC

Part V7 Tax planning
Part V7 Tax planning | Commentary

V7.189F Disaggregation—effect of a direction issued by HMRC

Part V7 Tax planning | Commentary

V7.189F Disaggregation—effect of a direction issued by HMRC

A positive point is that HMRC cannot issue a direction on a retrospective basis. This is confirmed in VATA 1994, Sch 1, para 2:

“The persons named in the direction shall be treated as a single taxable person carrying on the activities of a business named in the direction and that taxable person shall be liable to be registered under this Schedule with effect from the date of the direction or, if the direction so provides, such later date as may be specified therein.' (emphasis added)

The above regulation means that separation could prove

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