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Finmeccanica Group Services SPA v CRC, Upper Tribunal (Tax and Chancery Chamber), 23 July 2015
FGS an Italian company claimed the repayment of VAT charged to it by suppliers in connection with the provision of an enclosure at the Farnborough International Airshow.
Under the Refund Directive a refund is available only if the taxable person claiming it does not make any supply in the UK. HMRC said the taxpayer in providing the service to its sister companies made a supply in the UK because the supply entailed organising a fair or exhibition that was deemed to be made in the UK.
The general location rule was that the place of supply of services was the place where the recipient’s business was established if the recipient was a taxable person or if the recipient was a non-taxable person the place where the supplier was established. Since the...
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