VAT deduction on costs incurred in relation to the acquisition of a reversionary interest in a property subject to a legacy lease

Appeal Commissioners’ Cases

72TACD2021 – Appellant v Revenue Commissioners – 23 February 2021

Appeal Commissioner [AC] decided that the services supplied to the appellant and the circumstances in which the transaction occurred,
there was an objective link between the costs incurred by the appellant in connection with the acquisition of the reversionary interest in the property and the economic activity of the appellant as a whole – i.e. the exploitation of tangible property
for the purposes of obtaining income therefrom on a continuing basis – to establish a direct and immediate link to give rise to a right to deduct the VAT in full.