TC09666 - [2025] UKFTT 01253 (TC)

This appeal concerns whether the Appellant is entitled to reclaim input tax in respect of fees incurred in connection with the purchase of a parade of let retail units known as Cornwall Place, Buckingham (“the Property”). The issues in the appeal are whether the Appellant had valid VAT invoices and (whether or not the Appellant had valid VAT invoices), whether HMRC were entitled to deny input tax recovery.

HMRC’s assessments as appealed to the Tribunal also included an assessment for undeclared output tax on rent apportioned as part of the purchase by the Appellant of the Property. Following a discussion in the hearing Ms Donovan for HMRC, rightly in our view, withdrew HMRC’s assessment in this point and accepted the Appellant was not liable for the output tax. We therefore do not need to consider this issue any further.

All statutory references are to the Value Added Tax Act 1994 and references to regulations are to the Value Added Tax Regulations 1995 unless specified otherwise. The relevant legislation and regulations are set out in the Appendix to this decision.