Management activities and the right to input tax deduction

25 Feb 2016 | by Monckton Chambers

This article was first published on Lexis®PSL Tax on 22 February 2016. Click for a free trial of Lexis®PSL.

Tax analysis: Frank Mitchell, barrister at Monckton Chambers, explains the recent case involving Norseman Gold Plc which dealt with the practical application of the right to input tax deduction in respect of management activities being carried out by holding companies.

Original news

Norseman Gold plc v Revenue and Customs Commissioners [2016] UKUT 69 (TCC), [2016] All ER (D) 94 (Feb)

The Upper Tribunal (Tax and Chancery Chamber) (UT) dismissed the appeal by the taxpayer company against a decision of the First-tier Tribunal (Tax Chamber) (FTT) dismissing the taxpayer’s claim for recovery of input tax on the basis that  the supplies it had made to its subsidiaries had not been supplied for a consideration and were therefore not taxable supplies within the meaning of section 5 of the Value Added Tax Act 1994 and article 2(1) of Directive 2006/112/EC.

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