- Cited — Dawson's (Wales) Ltd v The Commissioners for HMRC 2023-03-28
“… In his written submissions he also stated that the need for intention would be contrary to the principles of legal certainty: BLP Group plc v. CEC Case C-4/94 [1995] STC 424 at [24] and Sub One Ltd v. HMRC [2012] UKUT 34 (TCC), [15] and [2014] EWCA Civ 773, [43]. He says that this is also consistent with the approach adopted in R v…”
- Cited — The Commissioners for HMRC v Newey (t/a Ocean Finance) 2018-04-17
“…in, that taxpayers may choose to structure their business so as to limit their tax liability. In BLP Group Plc v Customs and Excise Commissioners (Case C-4/94) [1995] STC 424, [1996] 1 WLR 174, the Court ruled that “a trader’s choice between exempt transactions and taxable transactions may be based on a range of factors, including t…”
- Cited — The Commissioners for HMRC v University of Cambridge 2018-03-27
“…urn then first to the decisions of the Court of Justice. The obvious starting point is the decision in Case C-4/94 BLP Group v Customs and Excise Commissioners [1995] STC 424. BLP sought to deduct input tax which it had incurred on professional services in connection with the sale of the shares in a German subsidiary. The share sale…”
- Followed — The Commissioners for HMRC v University of Cambridge 2018-03-27
“…It follows from that principle as well as from the rule enshrined in the judgment of BLP Group plc v Customs and Excise Comrs (Case C-4/94) [1995] STC 424 at 437, [1995] ECR I-983 at 1009, para 19 according to which, in order to give rise to the right to deduct, the goods or services acquired must have a direct a…”