Ince Gordon Dadds LLP v HMRC

In Ince Gordon Dadds LLP v HMRC [2023] UKFTT 44 (TC) (16 January 2023) the FTT decided that VAT on costs incurred for the purpose of raising funds to make acquisitions to which the representative member of a VAT group would supply management services was not recoverable. The costs were not incurred by the company that intended to supply the management services but by a company that did not itself have any actual or intended business activities at the time the costs were incurred.

The fundraising exercise involved an unlisted representative member of a VAT group obtaining a public listing on the alternative investment market (AIM) via a reverse takeover involving an AIM listed company known at the time as Work Group plc (WG). At the time of the takeover WG did not have any actual or intended business activities.

On the day the takeover took effect ...

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