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09 November 2009
Issue: 4231 / Categories: Tax cases , VAT
R (on the application of the Medical Protection Society Ltd) v CRC, Queen’s Bench Division

The Medical Protection Society Ltd provides support to members mainly doctors and dentists who face legal regulatory or disciplinary claims or proceedings in relation to their practices.

After an inspection of the society’s books by HMRC it was required to account for VAT for the three years to 14 January 2008 under the reverse charge provisions (VATA 1994 s 8) as a recipient of legal services. The total amount of VAT claimed was more than £5.8 million.

The society appealed claiming that a specific ruling by HMRC contained in a letter dated 3 March 1998 stated that it was not due to pay reverse charge VAT.

HMRC accepted that the letter contained a ruling in the taxpayer’s favour but said it was not valid because the society had not provided full details. These details...

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