The respondent sought to deduct input tax from income it received from lettings. It had previously occupied the buildings itself making exempt supplies, but then let them. They later waved their exemption, and sought to deduct input tax for periods prior to the election. One issue was whether a lease was one supply or a … Continue reading Commissioners of Customs and Excise v Royal and Sun Alliance Insurance Group Plc: CA 9 Oct 2001

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