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First Contact Ltd v HMRC

In First Contact Ltd v HMRC (TC01780 – 7 February) a company (F) supplied foreign exchange services. Most of its customers were young people whose usual home was in Australia New Zealand or South Africa but who were visiting the UK on extended ‘working holidays’. It accounted for VAT on the basis that it was entitled to credit for input tax on these supplies under VATA 1994 s 26(2)(c) as the customers’ usual place of residence was outside the UK. HMRC issued assessments on the basis that the customers’ usual place of residence was in the UK so that the supplies were exempt from VAT. F appealed. The Tribunal dismissed the appeal holding on the evidence that at the time of the supplies the customers ‘belonged in’ the UK for the purposes of VAT (Input Tax) (Specified Supplies) Order 1999...

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