No. 18,230

Decision given on 17 July 2003 by Mr Clark (Chairman).

Input tax – Attribution – Share issue – Accountancy fees covering share issue and audit – Basis for attribution where some shares issued outside EU – Whether complete code in Value Added Tax Regulations 1995 (SI 1995/2518), reg. 103 or additional attribution under reg. 101 – Directive 77/388, the sixth VAT directive, art. 17 and 19; Value Added Tax Act 1994, s. 4(2) and 26; Value Added Tax (Input Tax) (Specified Supplies) Order 1999 (SI 1999/3121).

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