In the case of Lloyds Banking Group, HMRC sought to unpick a batch of contracts, such that payments relating to a TUPE constituted consideration for a supply, leading to a £5m assessment. I am pleased to report that the First Tier Tribunal rejected this argument.
But the case is a warning that HMRC may seek to ‘drill down’ into ordinary commercial arrangements in their quest for revenue.
The decision is here: http://financeandtax.decisions.tribunals.gov.uk//Aspx/view.aspx?id=10197
About Les Howard
Hi, I am a VAT Consultant, working mainly with charities. I am based in Cambridgeshire
I have over 20 years experience in VAT, and am currently also a part-time member of the Tax Tribunals.