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Return of Q

05 August 2014 / Adrian Houstoun
Issue: 4463 / Categories: Comment & Analysis , holding companies , VAT

The decision in African Consolidated Resources has important VAT implications for holding companies


  • Holding companies will often be keen to recover their input VAT.
  • Initially European cases appeared to have little effect on UK VAT recovery.
  • In the ACR case HMRC stressed the absence of detailed contractual documentation between the companies.
  • The ECJ stresses the importance of an economic link between management services provided and the price paid for them.
  • What are the implications for fixed price contracts especially between related parties?

Fans of Star Trek will be familiar with the occasional character Q. He is a rather idiosyncratic member of the Q Continuum – a group of highly intelligent and apparently eternal beings – who turns up periodically to show various captains the error of their ways.

However unlike some of the other villains in the series...

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