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The Royal and Sun Alliance Group plc is the representative of its VAT group. Its subsidiaries held leases in five properties ranging from 15 to 25 years and in each case the landlord had exercised its option to tax the rents. Initially Royal and Sun Alliance occupied the properties but in the early 1990s it decided to sub-let them. In November 1995 the company exercised the right of election for the sub-lettings and thus any future sub-lettings were necessarily taxable supplies.
Since that date Royal and Sun Alliance claimed and was allowed credit for the input tax payable by it on the rents due to the landlords of the five properties. It claimed repayment of input tax incurred on rents and service charges in respect of the properties in the periods when they were vacant up to the making of the...