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In TLLC Ltd v HMRC (TC02857 – 13 September) a company (T) reclaimed input tax on professional fees relating to the sale of shares in subsidiary companies. HMRC issued an assessment to recover the tax on the basis that the input tax related to exempt supplies. T appealed. The First-tier Tribunal dismissed the appeal holding that T’s sale of the shares in the subsidiaries was an economic activity and was an exempt supply.

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Why it matters: The First-tier Tribunal upheld HMRC’s contention that the sale of shares in subsidiary companies was an exempt supply so that the company was not entitled to reclaim the related input tax.

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