VAT: Partial exemption
In St Johns College Oxford v HMRC (TC00424 – 6 May) a university college which was partly exempt had agreed a special method of attributing its input tax. It subsequently formed the opinion that this method did not give sufficient credit for input tax which it had incurred. In 2003 it proposed an alternative special method which HMRC rejected.
In 2004 the college sent a letter to HMRC expressed as being a 'special method override notice' under VAT Regulations 1995 (SI 1995/2518) reg 102C. HMRC accepted the notice and the college then submitted a repayment claim for £147 000. HMRC rejected the claim and the college appealed.
The tribunal reviewed the evidence in detail and observed that 'the college had material activities which were funded broadly by the endowment income of the college and which were not concerned...
