Value added tax – Input tax. The taxpayer company had not used the equipment at issue for taxable purposes and had not been acting in the capacity of a taxable person for VAT purposes, with the result that it was not entitled to recover VAT on approximately £4.5m incurred on the leasing and purchase of that equipment. Consequently, the Upper Tribunal (Tax and Chancery Chamber) dismissed the taxpayer's appeal against the decision of the First-tier Tribunal (Tax Chamber).