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Was the payment for use of the property an exempt supply of land or a standard-rated ‘management charge’?

By Andrew Needham, April 2025

Summary 

The appeal related to a claim to recover input tax on expenditure incurred by the appellant on the acquisition and refurbishment of property at Kingsland Wharf, Hackney. The appeal is against a decision by HMRC in May 2021 and upheld on statutory review to disallow an input tax claim in respect of a sum of £341,487.31 on the appellant's first VAT return. 

Background 

The appellant was a registered charity established by Alexander McQueen, the late fashion designer which owns a long lease in the property and employs a number of staff. Suture Inc Limited (SIL) is a wholly owned subsidiary, has no employees and is not registered for VAT. The appellant described its business activities as "collaboration projects" and "educational consulting". The appellant would "manage and co-ordinate marketing projects i.e. commission work of one or two artists in residence

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