Whose supplies?

The taxpayer company was suffering financial problems in 2002 when it entered into tripartite agreement with various financial institutions that had lent it money and PwC: the accountancy giant would carry out a review of the taxpayer which would be responsible for PwC’s fees expenses and disbursements.

The taxpayer claimed input tax on the costs in its VAT returns. HMRC refused so the company appealed.

The First-tier Tribunal allowed the appeal after Referring to CCE v Redrow Group [1999] STC 161 which concerned a similar arrangement.

The Revenue appealed arguing the agreement provided for PwC to supply services to the financial institutions not the taxpayer.

The Upper Tribunal (Tax and Chancery Chamber) agreed with the taxman. The taxpayer appealed.

The hearing was adjourned pending the Supreme Court decisions in CRC v Loyalty Management [2013] STC 784 and WHA Ltd and another v CRC [2013]...