Tax

Inventive Tax Strategies Ltd & Ors v Revenue and Customs (VAT - REPAYMENTS)

[2017] UKFTT TC TC06094First-tier Tribunal (Tax)2017

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VAT � Article 90 Principal VAT Directive � Regulation 38 VAT Regulations 1995 - whether price reduced after supply by contractual obligation to refund fees and credit note where no amount repaid and impossible to ascertain amount that will be repayable if any � what conditions must be satisfied to create entitlement to refund of fees - appeal dismissed

Sitting in public at the Royal Courts of Justice, Strand, London on 22 and 23 May 2017

Peter Mantle, counsel, instructed by Pinsent Masons LLP, solicitors, for the Appellants

Hui Ling McCarthy, counsel, instructed by the General Counsel and Solicitor to HM Revenue and Customs, for the Respondents

The Appellants are four companies: Inventive Tax Strategies Ltd (�ITS�); Professional Advice Bureau Ltd (�PAB�); Sterling Tax Strategies Limited (�STS�); and Bell Strategies Limited (�Bell�).� ITS and PAB are in administration.� STS and Bell are in liquidation.� The joint administrators and joint liquidators are Mr Finbarr O�Connell and Mr Henry Shinners of Smith & Williamson LLP.� They were appointed as administrators in October 2013 (for ITS) and December 2013 (for the other Appellants).�

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