Queen’s Bench Division (Crown Office List).

Auld J.

Judgment delivered 11 January 1995.

Value added tax – Input tax – Partially exempt reinsurance company – Attribution of input 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(1)(b).

  This was an appeal by Customs against a decision of the VAT tribunal ((LON/92/2485) No. 10,996; [1994] BVC 666) that fees paid for legal services incurred by an insurer in disputing its liability under a contract of reinsurance were wholly attributable to the contract.

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