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New queries, issue 4443

11 March 2014
Issue: 4443 / Categories: Forum & Feedback

Bring on the sub; Loan account refund; To carry or not?; LLP problems

Bring on the sub

The use of a trading subsidiary by a charity to recover VAT on professional fees.

Our client is a charity that is not VAT-registered. It is considering whether to undertake a building project using a VAT-registered trading subsidiary with the aim that this will enable the VAT on professional fees to be recovered. Our basic thoughts are as follows.

  • If a charity engages the professionals directly the charity would have to pay VAT on their fees and would not be able to reclaim.
  • If the subsidiary engages the professionals and is VAT-registered it could reclaim.
  • The subsidiary charges a management fee for the project to the charity on which VAT applies.
  • If the management fee and its VAT are of the same level as the professional fees overall...

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