The UK Supreme Court ruled on 15 January 2026 that VAT on professional costs incurred in connection with a VAT‑exempt share disposal is not recoverable, rejecting any general fundraising exception. The decision applies to corporate groups where the parent provides taxable management services to a subsidiary, confirming that share sales remain within the scope of VAT but exempt, and that VAT grouping does not alter this treatment. Taxpayers must therefore plan for non‑recoverable transaction costs when restructuring or disposing of subsidiaries.
It ruled that VAT on professional costs incurred in connection with a VAT‑exempt share disposal is not recoverable, rejecting any general fundraising exception.
No, the Court explicitly rejected a general fundraising exception, stating recovery cannot be based on the intended use of proceeds.
Costs must have a direct and immediate link to the share sale itself; indirect links to the parent’s business do not justify recovery.
No, VAT grouping does not extinguish business activities; the share sale remains within the scope of VAT but exempt.
Transaction‑specific advisory and deal execution costs on share disposals are typically not recoverable, so careful budgeting for such costs is essential.
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HMRC · about 14 hours ago
This guidance handbook from HMRC explains customs authorisations in detail, covering their purpose, eligibility, application procedures, compliance requirements, guarantee types, authorisation management, appeals, renewal, and the legal framework. It serves as a technical reference for businesses and customs officials to correctly apply for and manage customs authorisations.
Supreme Court · 1 day ago
The UK Supreme Court is hearing a case on whether Hotel La Tour Ltd can recover the VAT paid on professional fees incurred to facilitate the sale of shares in its subsidiary. The dispute centers on the link between the input VAT and the company’s taxable activities. The judgment, issued 17 December 2025, will clarify the recoverability of such VAT in similar share‑sale contexts.
vLex · 1 day ago
The First‑tier Tribunal (Tax Chamber) upheld HMRC’s VAT liability ruling that Story Terrace Limited’s supplies are standard‑rated ghost‑writing services, not zero‑rated books. The decision, issued on 11 December 2025, confirms the classification under the Value Added Tax Act 1994.
TaxScape · 3 days ago
The Deloitte TaxScape weekly VAT news update covers a First‑tier Tribunal ruling that allows Littlewoods to recover full input tax on photography costs, the withdrawal of HMRC’s linked‑goods concession under the ESC, and significant changes to the EU Deforestation Regulation effective 30 December 2026 for large and medium businesses. It also notes the removal of printed materials from the EUDR scope and the publication of these changes in the Official Journal on 23 December 2025.
UK Government · 3 days ago
The UK Government brief confirms that the VAT exemption for deputising services extends to all temporary medical staff, including locum doctors supplied by employment businesses, following a 2025 First Tier Tribunal ruling. Businesses that have charged standard‑rate VAT on such supplies within the last four years can claim a refund via an error‑correction notification. The brief also outlines the steps for claiming refunds and the impact on recovered input tax.
Bloomberg Tax · 4 days ago
The UK First‑Tier Tax Tribunal ruled on 16 December 2025 that photography costs used for product catalogues and an online store by an online retailer with integrated financial services are fully recoverable input VAT, as they are used for taxable retail supplies. The decision clarifies that such costs are not partially recoverable due to mixed use with exempt financial services.
