Victoria Oil & Gas FTT Rules on VAT Recovery for Holding Company

The FTT upheld HMRC’s input VAT assessments as made to best judgment, finding the officer had made an honest and reasoned assessment after repeated information requests and inconsistent explanations from VOG.
VOG, a holding company, made taxable supplies for consideration to overseas subsidiaries, which in principle gave a right to VAT recovery.
Input VAT on management, administration, operation of the subsidiaries, and litigation/dispute costs directly connected to those taxable supplies was recoverable.
Litigation and legal costs not linked to the subsidiaries’ business were not recoverable because no reciprocal taxable supply was shown.
VOG was not entitled to full recovery on a “wholly taxable” basis, as it also carried out non-economic activity in relation to other subsidiaries without consideration or expectation of remuneration; the appeal was allowed only in part, with apportionment to be agreed.

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.