- Hotel La Tour sold shares to fund construction of a new hotel
- HLT claimed VAT recovery on legal and PR costs associated with share sale
- FTT and UTT agreed with HLT’s claim, but CoA ruled in favor of HMRC
- CoA decided costs were directly attributable to VAT exempt share sale
- Vendors should factor in irrecoverable VAT in share sale transactions
- Some pre-transaction due diligence costs may be recoverable at HMRC’s discretion
- Key takeaways: consider structuring arrangements differently for VAT recovery on costs
Source: claritastax.co.uk
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.
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