The landlord had elected to waive exemption to charging VAT on its lettings. The tenant relet the demised premises, but at first without charging VAT. It later charged VAT on the sublease, but the commissioners objected to the attempt of the claimants under regulation 109 to reclaim the VAT it had itself paid before that … Continue reading Royal and Sun Alliance Insurance Group plc v Her Majesty’s Commissioners of Customs and Excise: HL 22 May 2003