The UK Supreme Court’s 2025 decision in HMRC v Hotel La Tour Ltd clarified that input VAT on professional fees linked to a share sale is irrecoverable because the costs are directly tied to an exempt supply. The ruling confirms that the direct and immediate link test applies to share sales and that being part of a VAT group does not allow recovery of such fees. The judgment underscores the need for careful documentation to distinguish between exempt and out‑of‑scope transactions.
The VATfaqs digest
Global VAT news, delivered Tuesday and Thursday. Free, curated from 50+ official sources, no spam.
No spam · Unsubscribe any time
Energy Digital · about 7 hours ago
UK: New Prime Minister Andy Burnham will cut VAT on electricity bills from the start of October, exempting households in England, Scotland and Wales for six months. The measure will reduce average household bills by about £45 and cost the Treasury roughly £850m this financial year.
TaxResearch · 1 day ago
The UK will remove VAT from electricity bills from October, cutting average annual bills by about £45 per household. The move is expected to reduce tax revenue by roughly £1.1 billion, but critics argue it does not address underlying grid capacity issues.
Guardian · 1 day ago
The UK government will remove VAT from electricity bills for households in Great Britain from 1 October 2026, reducing the annual price cap by £45. Northern Ireland will retain the 5% VAT rate, and the cut does not apply to gas.
VatCalc · 1 day ago
The United Kingdom has announced that domestic electricity bills will be zero-rated from 1 October 2026, reducing the VAT rate from 5% to 0%. The measure is temporary, applying until 31 March 2027, and will be funded by cancelling the planned Digital ID programme.
The Independent · 2 days ago
The UK government will remove VAT from domestic electricity bills from 1 October 2026, cutting the rate from 5% to 0%. The change is expected to save households around £45 a year and will be funded by cancelling the Digital ID programme.
The Independent · 2 days ago
In the UK, the government announced an £850 million tax cut on energy bills, making electricity bills VAT free from 1 October 2026 in England, Scotland and Wales. Northern Ireland remains exempt because EU VAT rates apply under the Windsor Framework, preventing the cut from applying there.
Put your brand alongside trusted tax-tech intelligence across 150+ countries.
Key Takeaways
The Court held that input VAT on professional fees incurred for the share sale was irrecoverable because the fees were directly and immediately linked to an exempt supply.
The Court confirmed that the direct and immediate link test applies to share sales, meaning costs directly attributable to the exempt share sale cannot be recovered as input VAT.
No; the Court ruled that being part of a VAT group does not allow recovery of professional fees incurred for an exempt transaction.
Input VAT on exempt supplies is irrecoverable, whereas input VAT on out‑of‑scope supplies may still be recoverable as part of general overheads.
Primary source
Read the full article at JDSupraThis summary was published on VATfaqs.com on 30 January 2026. It relates to VAT developments in United Kingdom. The original source is JDSupra.