HMRC has extended its losing streak against law firms that take leases through a subsidiary company. Chris Nyland (Scammell & Nyland) explores why HMRC keeps attacking the same structure, and how better to ensure that it doesn’t win.
Every 18 years HMRC has litigated against a firm of solicitors that has taken a lease of premises in a name other than the firm’s own. In each case HMRC argued against recovery of VAT by the firm. And each time so far HMRC has lost. In 1986 it went unsuccessfully after Bird Semple & Crawford Heron ([1986] VATTR 218). In 2004 it was bested by Lester Aldridge (VTD 18864). In 2022 it was the turn of Ashtons Legal to taste victory ([2022] UKFTT 422).
This is a streak not only in the sense of a recurrent pattern but also in the sense of...
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HMRC has extended its losing streak against law firms that take leases through a subsidiary company. Chris Nyland (Scammell & Nyland) explores why HMRC keeps attacking the same structure, and how better to ensure that it doesn’t win.
Every 18 years HMRC has litigated against a firm of solicitors that has taken a lease of premises in a name other than the firm’s own. In each case HMRC argued against recovery of VAT by the firm. And each time so far HMRC has lost. In 1986 it went unsuccessfully after Bird Semple & Crawford Heron ([1986] VATTR 218). In 2004 it was bested by Lester Aldridge (VTD 18864). In 2022 it was the turn of Ashtons Legal to taste victory ([2022] UKFTT 422).
This is a streak not only in the sense of a recurrent pattern but also in the sense of...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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