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Norseman Gold v HMRC

In Norseman Gold v HMRC (TC 03698 – 12 June 2014) the FTT held that the taxpayer was not entitled to recover input tax as it had not charged for its supplies.

HMRC had denied claims for the recovery of input tax on the ground that the taxpayer was not carrying out an economic activity. In the alternative HMRC argued that the input tax claimed was not attributable to any taxable supplies.

Norseman Gold is a UK registered company listed on AIM. It is a holding company for subsidiaries which carry on mining activities in Australia. It is registered for VAT with the trade classification ‘management consultancy’.

Referring to BAA [2013] STC 752 the FTT observed that Norseman Gold’s directors played an active part in the direction of the subsidiaries spending ‘material amounts of time on the subsidiaries’ activities’. Consequently the ‘direct and indirect involvement’...

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