In HMRC v Volkswagen Financial Services (UK) Ltd (Upper Tribunal – 19 November) a company (V) which sold motor vehicles under hire-purchase agreements had agreed a special partial exemption method for calculating its recoverable input tax. It attributed part of its residual input tax to its taxable supplies of goods and part to its exempt supplies of finance using a ‘transaction count’ method. HMRC issued an assessment on the basis that V had failed to comply with the guidelines in Revenue & Customs Brief 82/09 and that some of the input tax should have been treated as wholly attributable to exempt supplies. The First-tier Tribunal allowed V’s appeal but the Upper Tribunal reversed this decision holding that ‘the residual cost inputs in this case have no direct and immediate link with...
