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The VAT briefing for September 2015

Lee Squires and Fiona Bantock (Hogan Lovells) examine the recent decisions in Volkswagen Financial Services, Hilden Park and Redcats (Brands), and review recent HMRC briefs and consultations.
 

VWFS: partial exemption – attribution of residual input VAT

 
The Court of Appeal’s (CA) decision in Volkswagen Financial Services (UK) Limited v HMRC [2015] EWCA Civ 832 (VWFS) (reported in Tax Journal 7 August 2015) concerned what is a fair and reasonable apportionment of residual input VAT in respect of hire purchase (HP) transactions by VWFS. VWFS and HMRC were unable to agree how the recoverable proportion of the input VAT should be calculated under the partial exemption special method (PESM). 
 
Both parties put forward methodologies

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