HMRC鈥檚 VAT appeal update has confirmed that this case will be heard in June 2025. For background, the taxpayer was a holding company and decided to dispose of a 100% owned subsidiary by way of an exempt share sale to finance the development of a new hotel that would generate taxable income. The original FTT supported the taxpayer鈥檚 argument that there was a direct and immediate link between the VAT on the professional fees and the downstream taxable services and the VAT was not a cost component of the exempt supply. HMRC鈥檚 appeal was dismissed at the UT but the decision was overturned at the CoA. To access the earlier CoA judgment, click聽.
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