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Airline Placement and disclosure

05 June 2023 / Andrew Hubbard
Issue: 4891 / Categories: Comment & Analysis , HMRC , TMA 1970 , UK VAT , Business , Companies , VAT
‘Smudging it all over’

Key points

  • The Airline Placement case concerns when and where a VAT charge would arise but also concerns the wider issues about disclosure and reliance on HMRC rulings.
  • Though mooted and consulted on the UK has never had a full legislative regime for binding rulings or pre-transaction clearances from HMRC.
  • In which circumstances can any sort of ruling statutory non-statutory or informal be relied on?
  • HMRC must know how the ruling is to be used and to be binding the ruling must be clear and unqualified.
  • Matrix-Securities: the ‘there but by the grace of God go I’ case.
  • The key finding in the Airline Placement case was that the disclosure had been inaccurate and misleading and hence the taxpayer could not rely on it and HMRC had the right to withdraw it.

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