VDT VALUE ADDED TAX – avoidance – construction of premises for probable occupation by partially-exempt banking group – series of transactions designed wholly or partly to reduce liability for VAT – assumption that tribunal’s decision in Halifax plc correct – whether transactions artificial – whether tax avoidance sole purpose
VALUE ADDED TAX – Sixth Directive arts 17, 19, 20 – VAT Regulations 1995, reg 101 – residual input tax – intention to make future taxable and exempt supplies – fixity of intention – whether necessary for application of reg 101(2)(d) – effect of change of intention – whether absence of demonstrable intention to make identifiable taxable supply renders reg 101(2)(d) inapplicable
VALUE ADDED TAX – building – meaning – VATA Sch 9 Group 1 – whether new construction attached to existing structure by link bridge with shared services and used for same purposes to be regarded as a ‘building’ in its own right or merely an extension of the original building – whether Sch 8 Group 5 Note (16) concepts relevant – Sixth Directive art 4(3)
Citations:
[2004] UKVAT V18642
Links:
VAT
Updated: 11 June 2022; Ref: scu.199159
