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In Imprimatur Capital Holdings Ltd T vs HMRC [2021] TC08006, the First Tier Tribunal (FTT) concluded that only the services to third-party clients were made for consideration, therefore amounted to an economic activity and entitled to input tax recovery on those services.

This is a complex case about the right to an input tax deduction and whether there is a direct link between consideration and supply.

The fees charged to portfolio companies were deferred until the portfolio company could afford to pay for the services.

In 2016 HMRC disallowed input tax deducted of £102,205 for the periods June 2012 to June 2015. A review by HMRC in 2017 upholding their 2016 decisions and to disallow input tax deducted of £82,609 for the periods December 2015 to March 2017.

Imprimatur Capital appealed against a review to the FTT.

The FTT concluded that:

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External Link

Imprimatur Capital Holdings Ltd v HMRC [2021] TC 08006


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