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AC Tours v HMRC

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In AC Tours v HMRC (TC00645 – 2 September), a UK partnership supplied hotel accommodation and organised tours to overseas companies which arranged tours in the UK. HMRC issued a ruling that the place of supply was in the UK, where the partnership belonged. The partnership appealed, contending that part of the consideration which it received should be treated as attributable to supplies of information, falling within VATA 1994 Sch 5 para 3. The Tribunal rejected this contention and dismissed the appeal.

Why it matters: It is an accepted principle that for VAT purposes, supplies should not be ‘artificially split’. The Tribunal here had little difficulty in upholding HMRC’s contention that there was a single supply to each customer.

Issue: 1047
Categories: Cases