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M Reid v HMRC

In M Reid v HMRC (TC02655 – 19 April) a solicitor (R) provided intermediary services for prospective purchasers of capital redemption bonds. He did not account for tax on such supplies treating them as exempt. HMRC issued an assessment charging tax on the basis that the supplies failed to qualify for exemption and that certain entries in R’s books constituted payment of the supplies. R appealed contending as a preliminary point that the book entries did not constitute payment. The First-tier Tribunal accepted this contention and allowed the appeal (without deciding the substantive issue of whether the supplies were taxable or exempt).

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Why it matters: In Pentex Oil Ltd v C & E Commrs (VTD 7989) a holding company had made supplies to two subsidiary companies the value of which was recorded by credit and debit entries in the companies’...

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