Commentary

V7.359 HMRC approach to partial exemption special methods

Part V7 Tax planning
Part V7 Tax planning | Commentary

V7.359 HMRC approach to partial exemption special methods

Part V7 Tax planning | Commentary

V7.359 HMRC approach to partial exemption special methods

The key aim of any officer reviewing a special method application, or subsequent review of the method on a VAT inspection, should be to ask the simple question: does this method give a fair and reasonable outcome as far as residual input tax recovery is concerned?

Rules introduced on 1 April 2007 put the onus on the taxpayer to certify that any proposed method is 'fair and reasonable' in terms of input tax recovery. If it is subsequently found to be unfair (and HMRC considers the taxpayer knew it would be unfair at

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