The Upper Tribunal in JTI Acquisitions dismisses the taxpayer’s appeal, agreeing with the First-tier Tribunal’s conclusions on the application of the unallowable purpose rule whilst identifying some non-material errors in its approach. In Hotel La Tour, the Upper Tribunal dismisses HMRC’s appeal, agreeing with the FTT that VAT incurred on advisers’ fees in relation to a share sale was recoverable as the share sale had the purpose of raising funds for the holding company’s taxable general activity. The latest HMRC annual report and accounts show a record £814bn tax revenues were raised in 2022/23, but customer service performance is below HMRC’s targets and historical performance levels.
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The Upper Tribunal in JTI Acquisitions dismisses the taxpayer’s appeal, agreeing with the First-tier Tribunal’s conclusions on the application of the unallowable purpose rule whilst identifying some non-material errors in its approach. In Hotel La Tour, the Upper Tribunal dismisses HMRC’s appeal, agreeing with the FTT that VAT incurred on advisers’ fees in relation to a share sale was recoverable as the share sale had the purpose of raising funds for the holding company’s taxable general activity. The latest HMRC annual report and accounts show a record £814bn tax revenues were raised in 2022/23, but customer service performance is below HMRC’s targets and historical performance levels.
If you are not a subscriber, subscribe now to read this content.
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