Ad Hoc Management v HMRC

In Ad Hoc Management v HMRC [2019] UKFTT 315 (16 May 2019) the FTT refused the taxpayer’s application for costs to be calculated on an indemnity basis.

Ad Hoc made arranged for individuals known as ‘property guardians’ to occupy vacant properties owned by third party clients. These were tripartite arrangements involving property owners Ad Hoc and the property guardians with property guardians paying fees to Ad Hoc in return for a right to occupy the premises. 

HMRC considered that supplies made by Ad Hoc to property guardians were not exempt lettings of immovable property. The appeal was determined in favour of Ad Hoc following the withdrawal of the assessments by HMRC. 

The appeal had been categorised as a complex case and the parties agreed that HMRC should pay Ad Hoc’s costs. The issue was the basis on which the appellant’s costs should...