The Supreme Court’s December 2025 ruling reaffirmed the BLP barrier, stating that VAT incurred on fees for share sales remains non‑deductible because of a direct and immediate link to an exempt supply. The decision effectively ends the argument that share‑sale proceeds can be used to recover VAT on overheads. Businesses must therefore plan VAT recovery strategies early and seek specialist advice before raising capital through share sales.
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Cumbria Crack · about 16 hours ago
The UK government’s Great British Summer Savings initiative introduces a temporary VAT reduction from 20% to 5% on certain children’s meals and family-focused activities from 25 June to 1 September 2026. Businesses must identify qualifying supplies, review pricing, adjust bundled offers, and update booking and accounting systems to manage mixed VAT treatments and potential advance‑booking adjustments.
Bournemouth Echo · 1 day ago
HMRC has confirmed that VAT‑registered companies in Dorset can donate goods to registered charities without incurring VAT, provided the goods are used to support people in need or deliver charitable services. This removes a barrier that previously required businesses to pay VAT on donated goods. Businesses should keep accurate records of donated items, especially high‑value goods.
Marcus Ward · 5 days ago
HMRC has updated Notice 742A to clarify the treatment of opted land and buildings, including the requirement to account for output tax on assets remaining on hand at the point of VAT registration cancellation and the removal of a temporary change to the notification time limit. The notice also outlines whether optors need HMRC permission before exercising the option and how to notify HMRC of the decision.
Irish News · 7 days ago
The UK Government has announced a temporary VAT cut for Northern Ireland hospitality, reducing the rate on tickets for theme parks, zoos and museums from 20% to 5% for the summer holidays of 2026. The move is part of a broader push to align Northern Ireland’s rates with the Republic of Ireland, where food and hospitality services will fall to 9% later this year. The decision is seen as a proof point for differentiated VAT policy to support the sector.
Greater Birmingham Chambers of Commerce · 16 days ago
The UK Chancellor announced temporary VAT cuts from 20% to 5% on family attractions during school holidays, effective from the end of June to 1 September 2026. Additional measures include free bus journeys for under‑16s in England in August, a 12‑month HGV road tax holiday, and a one‑third reduction in red diesel duty until the end of 2026. Business leaders argue the cuts are insufficient to support hospitality and other sectors.
Museums Association · 16 days ago
The UK government has introduced a temporary 5% VAT rate on admission to certain family attractions, effective from 25 June to 1 September 2026, replacing the standard 20% rate. The cut covers museums, planetariums, heritage sites, nature reserves, botanical gardens, children’s meals and performance‑venue tickets marketed for children, but excludes seasonal passes beyond 1 September unless priced similarly to day tickets. Charities already exempt from VAT do not benefit unless they operate through a VAT‑registered trading subsidiary.
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Key Takeaways
In December 2025 the Supreme Court held that the "direct and immediate link" test is the primary method for determining VAT deductibility, reaffirming the BLP barrier and confirming that VAT on share‑sale fees remains non‑recoverable.
No, the ruling confirms that VAT incurred on fees for disposing of subsidiaries through share sales remains an absolute cost and cannot be recovered.
It is the objective test used to determine VAT deductibility, requiring a direct and immediate link between the input services and the exempt supply; the Supreme Court emphasized that the economic purpose of the transaction is irrelevant.
Businesses must plan VAT recovery strategies early, seek specialist advice, and understand that VAT on share‑sale fees will not be recoverable under current law.
Primary source
Read the full article at ICAEWThis summary was published on VATfaqs.com on 5 March 2026. It relates to VAT developments in United Kingdom. The original source is ICAEW.
