Commentary

V7.193 Disaggregation—planning points to consider

Part V7 Tax planning
Part V7 Tax planning | Commentary

V7.193 Disaggregation—planning points to consider

Part V7 Tax planning | Commentary

V7.193 Disaggregation—planning points to consider

The following points should be given consideration.

  1.  

    •     If advising clients on the separation of business activities, it is important to ensure that avoidance of VAT is not the main motive for the arrangement.

  2.  

    •     Remember, there will only be a potential problem with HMRC if the arrangement results in HMRC losing VAT – two businesses with a combined turnover of less than the registration limits, or businesses selling wholly or mainly zero-rated items (where a registration would produce VAT repayments) is not a problem.

  3.  

    •     The emphasis on normal commercial arrangements between different entities

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