FTTTx VAT – partial exemption – CVCP Agreement between universities and HMRC – whether HMRC approved a new non-CVCP retrospective partial exemption special method (‘PESM’) from 1973 to 1994 – whether a combined business/non-business method was ultra vires – whether a PESM is valid if it is not fair and reasonable – whether non-inclusion of grant income in PESM means it was not fair and reasonable – further 1997 claim for residual VAT on overheads of academic departments – 1997 claim based on PESM but subject to three year cap – Fleming claim to recover further residual VAT for period from 1973 to 1994 – whether HMRC able to reopen earlier claims so as to include grant income – evidential issues – earlier years of Fleming claim dismissed for lack of evidence – adjournment of later years – directions given
[2015] UKFTT 0033 (TC)
Bailii
England and Wales
VAT
Updated: 27 December 2021; Ref: scu.542037