Kelly and another (trading as Ludbrook Manor Partnership) v Revenue and Customs Commissioners

Value added tax – Input tax. The First-tier Tribunal (Tax Chamber)(the FTT) had correctly dismissed the taxpayers' appeal against the Revenue and Customs Commissioners' decision to reject their claim for credit for input tax relating to the supply of work done on certain property by a company, HHL, (of which the taxpayers were directors) to a partnership which the taxpayers had subsequently formed. The Upper Tribunal (Tax and Chancery Chamber) so held in dismissing the taxpayers' appeal against the FTT's decision, having decided that the requisite reciprocity of obligation between the taxpayers, either as individuals or partners, and HHL had not existed at the time the relevant supplies had been made.

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