In its recent judgment in Investment Trust Companies (in liquidation) v Commissioners for HMRC [2015] EWCA Civ 82, the Court of Appeal in London found that investment trust companies (ITCs) could recover from the UK revenue authority, HMRC, the amount of the VAT they paid to their managers, who then paid it to HMRC, in each period claimed. However, they could not recover from HMRC the amount of any input tax set against their managers’ VAT liability. Instead, ITCs now must bring separate claims against their managers for these amounts.
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