Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

Virtually standard

05 July 2006
Categories: Tax cases
Abbey National plc v CRC, Court of Appeal, 29 June 2006

Abbey National owned 1 000 leasehold and freehold properties which in 2000 it agreed to sell to M Ltd. Abbey intended to lease back the properties that it wished to occupy. The shorter leases were transferred to M Ltd by a virtual assignment so that the economic benefits and burdens were transferred to M Ltd and Abbey paid a principal fee to M Ltd as if there had been a formal lease back. With regard to sublet properties M Ltd was entitled to receive rent from the underlessees. HMRC decided that in neither of these situations was there an exempt supply consisting of leasing or letting of immoveable property within the meaning of Article 13B(b)1 of the Sixth Directive. Rather there was a standard-rated supply of agency and property management services.
Abbey appealed. The VAT tribunal dismissed the appeal in relation to the...

If you or your firm subscribes to, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.

back to top icon