In Norseman Gold, the Upper Tribunal has confirmed that where management services are supplied by a holding company but the charge for those services is only set and levied subsequently, without any clear prior obligation, there is no consideration for VAT purposes. As a result, the services are not taxable supplies and the holding company has no entitlement to input VAT recovery. The case demonstrates an obvious prerequisite for input VAT recovery by holding companies: a clear, mutual understanding as to the services to be provided and the fees to be charged for them.
