No. 20,355

Decision given on 28 September 2007 by Mr Gordon Coutts QC (Chairman).

Input tax – Attribution – Company making exempt, taxable and foreign supplies – Partial exemption special method – Method in form of written direction – Interpretation of method – Whether interpretation subject to an overriding consideration of ‘fair and reasonable recovery’ – Whether agreed method stands until altered – Value Added Tax Regulations 1995 (SI 1995/2518), reg. 101–103; Value Added Tax (Input Tax) (Specified Supplies) Order 1999 (SI 1999/3121); EC Directive 77/388, the sixth VAT directive, art. 17.

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