MAN (91/1178)

No. 11,043

Decision given 24 August 1993.

Supply – Management services – Holding company making charges to subsidiaries – Pensions holiday – Normal pension charges to group members included in management charge – Whether charge a compound or multiple supply – Assessment including serious misdeclaration penalty – Whether assessment correct and if so whether there was a reasonable excuse.

  The issue was whether the appellant was entitled to deduct input tax on charges made by its holding company which included charges made in lieu of pension fund contributions.

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