Hotel La Tour Ltd v HMRC

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In Hotel La Tour Ltd v HMRC [2023] UKUT 178 (TCC) (24 July) the Upper Tribunal (UT) dismissed HMRC’s appeal and upheld the First-tier Tribunal (FTT) decision that a company was entitled to recover VAT on the cost of professional services incurred in relation to the sale of shares in its subsidiary. This was because it found there was a direct link between the share sale and onward taxable supplies.

Hotel La Tour Ltd (HTL) was the 100% owner of a subsidiary and provided management services to it. Both companies were members of the same VAT group. The subsidiary owned a hotel in Birmingham which HLT decided to sell to fund the development of a new hotel in Milton Keynes. This was achieved through the share sale of the subsidiary.

HLT sought recovery of the VAT incurred on the marketing and legal costs associated with...

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© Copyright LexisNexis 2024. All rights reserved.

In Hotel La Tour Ltd v HMRC [2023] UKUT 178 (TCC) (24 July) the Upper Tribunal (UT) dismissed HMRC’s appeal and upheld the First-tier Tribunal (FTT) decision that a company was entitled to recover VAT on the cost of professional services incurred in relation to the sale of shares in its subsidiary. This was because it found there was a direct link between the share sale and onward taxable supplies.

Hotel La Tour Ltd (HTL) was the 100% owner of a subsidiary and provided management services to it. Both companies were members of the same VAT group. The subsidiary owned a hotel in Birmingham which HLT decided to sell to fund the development of a new hotel in Milton Keynes. This was achieved through the share sale of the subsidiary.

HLT sought recovery of the VAT incurred on the marketing and legal costs associated with...

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:

Subscribe Now...

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.

Once you have registered, you will receive an email directing you back to read this article in full.

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