TLLC Ltd: VAT recovery on fees for professional services

The First-tier Tribunal case of TLLC Ltd v HMRC [2013] UKFTT 467 (TC) looks in some detail at the principles established by the CJEU in relation to the recovery of input VAT. The tribunal found that a disposal of shares in companies which carried on a property rental business was an economic activity and could not be considered to be a transfer of a business as a going concern. The disposal was therefore an exempt supply, and the input tax incurred on professional fees in relation to the share disposal was irrecoverable.