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A Tanjoukian v HMRC

In A Tanjoukian v HMRC (Upper Tribunal – 25 October) an individual (T) who lived in Saudi Arabia paid £170 000 to purchase a vehicle registration number from the DVLA at an auction. The DVLA charged VAT on the supply. H appealed to the Upper Tribunal contending that the supply should be treated as taking place where he lived. Henderson J rejected this contention and dismissed the appeal holding that the supply was a supply of services and that the place of supply was where the supplier belonged which was in the UK. (A further ground of appeal concerning the principle of ‘legitimate expectation’ was stood over pending the Upper Tribunal decision in HMRC v Noor.)

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Why it matters: The Upper Tribunal upheld HMRC’s view that VAT was chargeable on the supply of a vehicle registration number. Henderson...

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