The Premspec Group Ltd v HMRC [2020] UKFTT 00167 (TC) (25 March) raises a small but important point about timing. To be recoverable input VAT must have been paid within six months of the relevant date (VATA 1994 s 26A): that is the latter of the date of the date of the supply and the date on which the consideration for the supply becomes payable. Here there was an informal arrangement between related companies where no date was specified for payment; in fact the taxpayer argued simply that the payment was due within ten years of one of the companies commencing to trade. HMRC argued that as there was no specified date the only date that could be considered was the date of the supply. As the consideration was not paid within six months of that date no input tax recovery was due. HMRC...
