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Visual Investments International Ltd (TC9292)
The taxpayer – Visual Investments International Ltd – claimed input tax on the cost of legal fees provided by a firm of lawyers Withers LLP. The services related to a ‘shareholder dispute’ involving another company SGP. The deal structure was as follows:
- Visual owned most of the share capital in a separate company BIG Ltd which was not registered for VAT and owned 39% of the shares in SGP.
- The activity of Visual and its director was to invest in start-up structures and provide consultancy services ‘to help them reach their full potential’.
- Visual claimed that input tax could be claimed on the legal services provided by Withers because they related to ‘professional fees to protect their investment’.
HMRC refused the claim. It concluded that BIG was the company that was ‘most closely connected’ with the supply of legal services but it was neither VAT...
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