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Melford Capital General Partner Ltd v HMRC

In Melford Capital General Partner Ltd v HMRC [2020] UKFTT 6 (TC) (30 December 2019) the FTT ruled that the general partner of an English limited partnership was entitled to recover VAT on the costs it incurred setting up and operating an investment structure.

The appellant was general partner of an English limited partnership (‘the fund’). The fund held the shares in a company incorporated in the Isle of Mann (HPH) which in turn held shares in various special purpose vehicles (‘the SPVs’). The SPVs held underlying assets such as commercial property. 

The complex structure was divided into two VAT groups. The appellant was VAT grouped with its parent LLP (‘the LLP’) and HPH was grouped with the SPVs. The LLP provided management services to both HPH and the SPVs. It also provided investment and administrative advisory services to the appellant.

The appellant in effect argued that this was...

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