Elliott: Pre-registration input tax issues in Sam Smith case

VAT expert Graham Elliott analyses the implications of the decision in the Sam Smith T/A Heliops case concerning pre-registration input tax

It is well-known that input tax can be recovered on costs pre-dating the date of VAT registration (and even incorporation), but subject to rigid time limits

These are six months retrospection for services, and four years for goods. The Tribunal decision in Sam Smith T/A Heliops UK [TC 04237] shows the importance of respecting these rules.

Captain Smith is a commercial pilot, and registered for VAT after having undergone an expensive training programme to equip him for his career.

His first apparent omission was to register some while after the training had been billed to him, without back-dating the effective inception of the registration.

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