LON (92/2485)

No. 10,996

Decision given 12 August 1993.

Input tax – Partial exemption – Attribution of tax on supplies of legal services – Whether attributable to taxable supplies relating to zero-rated insurance policies – Value Added Tax (General) Regulations 1985 (SI 1985/886), reg. 30.

  The issue was whether certain legal fees incurred by a reinsurance company which made zero-rated supplies to persons outside the EC were wholly or exclusively used in making such supplies or whether they were part of the taxpayer’s general overheads.

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