Halifax Plc Country Wide Properrty Investments Ltd and Another v Revenue and Customs: VDT 5 Jul 2001

Tax avoidance – Input tax – Partially exempt trader – Building works required for that trader’s business – Trader’s input tax recovery rate restricted – Scheme for fully taxable subsidiary of trader to incur expenditure on building works – Meaning of expressions ‘supply’, ‘economic activities’ and ‘business’ – Transaction carried out for tax avoidance purposes with no business purpose – Whether transactions designed to incur input tax in subsidiary qualify as supplies – No – Appeals dismissed – EC 6th Dir. Arts. 2 and 4
[2001] UKVAT V17124
Bailii
England and Wales

Updated: 16 October 2021; Ref: scu.247559