In a long-running case about input tax on services recharged to subsidiaries, AIM listed Tower Resources has won a ruling at the Upper Tribunal over a £600,000 disputed VAT reclaim
The original case began in 2016 with the appeal from Tower Resources on HMRC’s decision to deny it credit for input tax in the sum of £613,169.96 claimed for its VAT accounting periods December 2014 to December 2015 and to issue an assessment for £842,850 for VAT periods December 2012 to September 2014. This was on the grounds that Tower Resources did not make taxable supplies for consideration between its subsidiaries.
Tower Resources is a UK holding company which acquires licences to explore for and produce oil and gas in sub-Saharan Africa.
HMRC appealed the First Tier Tribunal’s (FTT) decision from a 2019 hearing, which ruled in Tower Resources favour, on three grounds.
These grounds were that FTT misunderstood HMRC’s case and failed to make complete findings of material fact about the agreement between Tower Resources and its subsidiaries.
