Recovery of VAT on corporate bid costs

KEY POINTS

• Input VAT can be recovered if there is a direct and immediate link between supplies received and taxable supplies made.
• The Court of Justice of the European Union distinguishes between buying shares for investment and economic activities.
• The letting of a building by a holding company to a subsidiary could constitute management.
• In the Ryanair case the Advocate General has suggested the importance of a ‘functional link’ between the share acquisition and business.
• To recover VAT on future bid costs management services remain important and should be documented.

A taxable person (a person who carries out in any place any economic activity) receiving supplies of goods and services for the purposes of its taxable transactions can recover the VAT levied on those supplies if there is...