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Cite as: [2007] UKVAT V20355

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Standard Life Assurance Company v Revenue & Customs [2007] UKVAT V20355 (28 September 2007)

20355

Input Tax – attribution – company making exempt taxable and foreign supplies – partial exemption special method – voluntary disclosure – method in form of a written direction – interpretation – whether interpretation subject to an overriding consideration of a "fair and reasonable recovery" – No – whether the agreed method stands until altered – Yes – whether repayment due – Yes. VAT Regulations 1995; 101-3 VAT (Input Tax) (Specified Supplies) Order 1999.

EDINBURGH TRIBUNAL CENTRE

STANDARD LIFE ASSURANCE COMPANY Appellant(s)

- and -

THE COMMISSIONERS FOR

HER MAJESTY'S REVENUE & CUSTOMS Respondents

Tribunal: (Chairman): T Gordon Coutts, QC

(Members): James D Crerar, WS., NP

R L H Crawford, BA., CA., CTA

Sitting in Edinburgh on Tuesday 28 and Wednesday 29 August 2007

for the Appellant(s) Colin Tyre, QC

for the Respondents Iain Artis, Advocate

© CROWN COPYRIGHT 2007.

DECISION

Introductory

In this matter the Tribunal heard evidence led by the Appellant from Neil Alexander Gilbert employed as their Tax Manager between 1997 and 2004 and Martin John Hall their Group Vat Manager since August 2004. The Respondents led evidence from their officers Callum Stewart Melville who was the Higher Officer employed at the large business service in Edinburgh. From about June 2000 to February 2004 he was the lead higher officer for the Appellant dealing with its Vat matters. There was also evidence led from Christopher David Roberts the Respondents National Business Manager from 1 April 2002 to 7 March 2006 and as such was the recipient of the responsibility for the Vat matters of the Appellant in mid-2004. The Tribunal was also referred to a witness statement by Stewart Ian Grant a senior officer who at the relevant time was a tax specialist full-time in the partial exemption unit of expertise. He conducted a reconsideration said to be independent, of the Commissioners decision with which we are concerned in March 2006. Mr Tyre did not consider that it would be necessary for him to give oral evidence or be cross-examined on his statement.

The Tribunal was also provided with an Agreed Statement of Facts. There were no issues of credibility arising. A considerable volume of correspondence was produced, detailing the background to the dispute, the history of the Appellants partial exemption special methods and the varying contentions of the parties.

The Appellant's main activities are the provision of assurance, insurance and banking services. It also provides investment services and has a portfolio of investment properties. There are also other activities, some taxable and some exempt.

The appeal concerns the refusal of two voluntary disclosures submitted by the Appellant on 2 November 2005 and 9 February 2006 for £2,545,450 and £10,313,234 respectively. The question in issue between the parties concerns the attribution of input tax to foreign and specified supplies pursuant to an agreement between the parties. The agreement in issue was set out in the Respondents' letter dated 4 April 2001. That letter also gives approval to the adoption by the Appellant of a partial exemption special method ("PESM") in terms of regulation 102 of the VAT Regulations 1995.

Question for the Tribunal

The Tribunal considered that the question for them was the interpretation of the Partial Exemption Special Method (PESM) agreed and directed in the Respondents said letter dated 4 April 2001. The question involves consideration of the form of the appeal which is directed against the Respondents' rejection of two voluntary disclosures submitted by the Appellant on 2 November 2005 and 9 February 2006 respectively, covering periods of account from period 11/2 to 9/05. The voluntary disclosures consist of applications for recovery of input tax which had previously been categorised as wholly attributable to exempt supplies but which the Appellant now considers ought to have been categorised as attributable partly to exempt supplies and partly to "foreign and specified" supplies.

The Voluntary Disclosures

The disputed voluntary disclosures are made up principally of residual input tax on costs incurred in the marketing, establishing and ongoing servicing of supplies of life insurance, pensions and related products and services by the Appellant's UK Life & Pensions business, plus savings products and related financial services supplied by Standard Life Bank ("the relevant supplies"). The relevant supplies include supplies to non-EU residents. The relevant supplies thus include specified supplies in terms of the VAT (Input Tax) (Specified Supplies) Order 1999, SI 1999/3121. There are no material supplies in issue save for exempt supplies and these specified supplies. By reason of the inclusion of specified supplies, the voluntary disclosures treat the relevant supplies as partly exempt and seek recovery of the residual input tax attributable to them at the rate prescribed by step 6 of the PESM.

Background to the 4 April 2001 Agreement

The Appellant had operated various PESMs with the express approval of the Respondents since at least 1987. On 8 November 1987 the Respondents gave approval to a special method in the terms set out in a letter produced to the Tribunal (the "1987 Method"). An adjustment of that method was approved on or about 13 December 1990 with effect from 1 April 1990 to impose a cap on the VAT recovery rate for the "Grey area" of 24.63%. "Grey area" is more fully discussed below. On 16 May 1998 the Respondents gave approval in the terms set out in a letter produced to a substitute method ("the 1998 Method"). That method retained the cap.

On 24 November 2000, the Appellant sought approval for a revised method in the terms set out in a letter produced, with a view, inter alia, to removing the cap. On 7 February 2001, the Appellant restated its proposals in the terms set out in a letter which was accompanied by demonstrative calculations. The Respondents responded in terms of their letter of 12 February 2001 to which the Appellant replied on 22 February with an amended proposal. That amended proposal formed the basis, with one adjustment, of the method approved on 4 April 2001.

The letter of 4 April 2001

In view of the importance of the whole terms of this letter from the Respondents all the relevant portions of it are reproduced.

"Duration of Method

You must use this method to calculate your recoverable input tax with effect from 16 February 2000 and you must use it until such times as the Commissioners approve or direct the termination of its use. The approval is given in the context of your current business structure and trading patterns. If there are any changes in these trading or business patterns and structures or the VAT group membership to such an extent that the agreed method no longer gives a fair and reasonable recovery of input tax, you should inform this office in writing immediately.

Taxable Supplies

The definition of "taxable supplies" for the purposes of this method are:

a. any supply of goods or services made in the UK (including the Isle of Man) other than an exempt supply unless that exempt supply is specified within an order made under the Value Added Tax Act 1994 s26(2)(c);

b. any supply made outside the EC specified in an order under the Value Added Tax Act 1994 s26(2)(c) which would be exempt if made inside the UK;

c. any supply made outside the UK that would be a taxable supply if made within the UK;

d. any exempt supply which has been subject to a waiver exemption under the Value Added Tax Act 1994 Schedule 10(2).

Exempt Supplies

The definition of "exempt supplies" for the purposes of this method are:

a. any supply of goods or services made in the UK (including the Isle of Man) which is exempt from VAT by virtue of the Value Added Tax Act 1994 Schedule 9 (as amended) (or equivalent provision of the 1983 Act) unless that exempt supply is specified within an order made under the Value Added Tax Act 1994 s26(2)(c);

b. any supply made outside the UK but within the EC that would be exempt if made within the UK;

c. any supply made outside the EC not specified in an order under the Value Added Tax Act 1994 s26(2)(c) which would be exempt if made inside the UK.

Recoverable Input Tax

You are to calculate your deductible input tax for each partial exemption year with effect from the year commencing 16 February 2000 on the following basis:

Taxable supplies of the Investment Department X 100

Total supplies of the Investment Department

Input tax attributed to taxable supplies of the Property Department x 100

Total input tax attributed to the Property Department (excluding non-deductible input tax such as motor cars and business entertainment)

Input tax attributed, directly or indirectly to taxable supplies X 100

Total input Tax (excluding non-deductible input tax such as motor cars and business entertainment)

This will be applied to the Grey Area, Lothian Road, 1 George Street and Staff Ratio within the Input VAT Expenses area.

All the above ratios are to be expressed as a percentage calculated to the nearest 2 (two) decimal places without rounding up.

Exclusions

In calculating the proportions at paragraph 4, 5 and 6 above, you should exclude from the numerator and denominator the value of all distorting supplies in the following categories:

Supplies made from branches situated outside the UK.

Supplies of capital goods you have used for the purpose of the business.

Incidental real estate supplies.

Self supplies.

Incidental financial supplies.

The value of any imported service.

The selling price of any car used in the business unless it is sold for a profit. If so, the difference between the buying and selling price should be included.

The value of any goods and services not supplied by way of business.

The value of any supply of any goods sold on in the same state in connection with a supply of finance.

Supplies by way of a transfer of a going concern(s) ("TOGC").

Supplies between companies in the VAT group".

The Law applicable to such an agreement

1. European Community Law

Article 17 of the EC Sixth VAT Directive ("the Sixth Directive") provides the right to deduct input VAT. The entitlement is in respect of input VAT on expenditure used for: (1) taxable transactions; (2) economic activities carried out in another country which would be taxable if made in the taxable person's country; and (3) certain exempt supplies to customers established outside the Community (articles 17(2)(a) and (3)(a) and (c)). Article 17(5) goes on to provide that where expenditure is used partly for deductible transactions, it may be deducted in part.

Article 17(5) begins:

"(5) As regards goods and services to be used by a taxable person both for transactions covered by paragraphs 2 and 3, in respect of which [VAT] is deductible, and for transactions in respect of which [VAT] is not deductible, only such proportion of the [VAT] shall be deductible as is attributable to the former transactions.

This proportion shall be determined, in accordance with Article 19, for all the transactions carried out by the taxable person."

Article 19 entitled "Calculation of the deductible proportion", in relevant parts reads as follows:

"1. The proportion deductible under the first sub-paragraph of Article 17(5) shall be made up of a fraction having:

as numerator, the total amount, exclusive of [VAT], of turnover per year attributable to transactions in respect of which [VAT] is deductible under Article 17(2) and (3),

as denominator, the total amount, exclusive of [VAT], of turnover per year attributable to transactions included in the numerator and to transactions in respect of which [VAT] is not deductible.".

Article 17(5) continues at the third sub-paragraph:

"However, the Member States may:

(a) authorise the taxable person to determine a proportion for each section of his business.;

and it states

(c) authorise or compel the taxable person to make the deduction on the basis of the use of all or part of the goods and services;"

Case law makes it clear that the entitlement to deduct arises where there is a direct and immediate link between the expenditure and output transactions in respect of which VAT is deductible. This is intended to relieve a trader entirely of the burden of VAT where the expenditure is for activities which are themselves subject to VAT or so treated (the "neutrality" principle). It is for the national court to apply the direct and immediate link to the facts and surrounding circumstances of each case: see e.g. Midland Bank plc v CCE (Case C-98/98) [2000] STC 501; BUPA Purchasing Limited and others v CCE [2003] STC 1203 ("BUPA") and CCE v Southern Primary Housing Association Limited [2004] STC 209.

Relying on art. 17(5)(c), the UK introduced sections 24(1) and 26(2) of the 1994 Act. The former subsection defines "input tax" as including the Vat on certain specified goods or services "used or to be used for the purpose of any business carried on or to be carried on."; while section 26(3) empowers the Commissioners to make regulations "for securing a fair and reasonable attribution of input tax to supplies within section 26(2)". The relevant regulations are Part XIV of the Value Added Tax Regulations 1995.

The Regulations

Regulation 101 provides the standard method of calculation. Key features of that method are: (1) the attribution to taxable supplies of input tax on such goods and services as are used exclusively for taxable supplies (recovered in full): and (2) the attribution (and disallowance) of input tax on such goods and services are used exclusively for exempt supplies. This is generally described as the principle of "direct attribution". Non-attributable input tax i.e. VAT on expenditure used indiscriminately for all transactions of the taxable person (usually called "residual input tax"), is recoverable in part. In the standard method this calculation is made using a formula based on the value of outputs: regulation 101(1)(d). That sub-paragraph reads:

"(d) there shall be attributed to taxable supplies such proportion of the input tax on such of those goods or services as are used or to be used by him in making both taxable and exempt supplies as beaRs the same ratio to the total of such input tax as the value of taxable supplies made by him bears to the value of all supplies made by him in the period". (emphasis added)

Regulation 103 provides for the attribution of input tax to out-of-country supplies. Subject to exceptions not relevant in the instant case, this regulation directs that input tax:

"used or to be used . in whole or in part in making . [out-of-country supplies] . shall be attributed to taxable supplies to the extent that the goods or services are so used or to be used expressed as a proportion of the whole use or intended use"

"Use" is not defined.

3. The LIPA case

The interaction of regulations 101 and 103 was clarified by the House of Lords in C.C.E.V Liverpool Institute of Performing Arts [2001] STC 891 The Institute ("LIPA") made taxable and exempt supplies within the UK. It also made out-of-country supplies in the form of advertising services supplied to a German company. LIPA operated the standard method which required non-attributable input tax to be recovered according to a formula based on the ratio of the values of taxable to total outputs. The issue was whether the value of out-of-country supplies should be used in the numerator and denominator of the formula. The Court of Appeal considered that "taxable supplies" in what is now regulation 101 excluded foreign supplies, and that "all supplies" in regulation 101 included taxable supplies and exempt supplies but did not include foreign supplies. The court held that new regulation 103 was intended to constitute a separate regime from new regulation 101 for foreign and other specified supplies. The taxpayer's appeal to the House of Lords was dismissed, their Lordships holding that art 17(5) coupled with art. 19 of the Sixth Directive did not insist on a value based approach to the apportionment of residual input tax. Member States were entitled to require that deduction be made on the basis of the use of all or part of the goods or services.

4. Special methods

Regulation 102(1) provides (with certain exceptions not relevant to the instant case) that:

"Subject to regulation 103, the Commissioners may approve or direct the use by a taxable person of a method other than that specified in regulation 101 ."

This is referred to as a "special method". Most special methods require direct attribution of input tax to the greatest extent possible: in effect they repeat regulation 101(1)(a) to (c). The Method is so framed. Where special methods differ from the standard method is in relation to non-attributable input VAT. It is common to find "sectorisation" i.e. where non-attributable input is allocated, on one or more bases, to separate sectors within the business. Calculation of the deductible proportion within each sector is then on a basis such as a value of outputs ratio, transaction count, use, or sometimes a combination of factors. It may be so framed that, in a value of outputs calculation, certain output values are included and others excluded. In essence, therefore, a special method is directed primarily at allocating and apportioning non-attributable input VAT.

In view of the Tribunal the House of Lords Decision does not assist in any determination of the meaning of "use".

Important Features of the Agreement of 4 April 2001

It must be noted that for the purposes of the agreement "taxable supplies" are defined, as also are "exempt supplies".

In the agreed process;

Step 1 deals exclusively with taxable supplies as defined and is apt to secure that specified supplies are also included.

Step 2 does not apply to matters in which there can be a dual "use" as here. Step 3 makes an allocation in relation to a particular matter of costs arising from IT systems.

Step 4 deals with the position of input tax in the investment department and that uses output tax as a proxy for "use".

Step 5 deals with the property department and the proxy for "use" there is input tax.

Step 6 similarly uses an input tax proxy for "use". At this stage it is noted that the word "disallowed" which featured much in the Respondents correspondence and submissions, as applied to a sector only occurs in step 3. We refer to this later.

Meaning of step 6 above

The Appellant contended that step 6 can be simply read as encompassing all inputs not attributed by the preceding steps and is worded as being general and all encompassing. The Respondents contended that there was a 'gap' in that there were specified matters which must operate as a limitation rather than as examples. If it was not so construed, it was argued, the "overriding objective of a fair and reasonable attribution of input tax would not be achieved". These broad approaches are discussed in more detail below, but the Tribunal found it helpful first to review the genesis of the method of 4 April 2001.

Beginning with the PESM of 1987, which was a method directed at the activities of the Appellants Investment Department. The direction for calculation of deductible input tax was as follows:

"1. Input tax should be attributed to the fullest extent possible, directly to taxable (including zero rated) or exempt outputs. Input tax which is directly attributable to exempt outputs is not deductible.

or

a. input tax on commission on sales within the UK and EEC must be isolated and treated as irrecoverable;

b. the remaining input tax should be apportioned and the deductible proportion determined by applying the fraction;

taxable outputs of Investment Department

total outputs of Investment Department;

Input tax attributed to taxable outputs of Property Department

total input tax of Property Department (less non-deductible such as cars, business entertainment)

Input tax attributed, directly or indirectly, to taxable outputs

total input tax (less non-deductible such as cars, business entertainment)"

It will be seen accordingly that in para 5 the un-attributable input tax was called residual. Residual was there described as "grey area". Whether that description originated from the Appellant or the Respondent does not particularly matter but it would appear to be plain that it was synonymous with the whole of the residual input tax.

For reasons which need not concern this Tribunal an amended PESM at para 5 continued the above description of residual tax omitting the inverted commas around grey area but adding

"the recoverable proportion calculated above shall apply subject to a maximum of 24.63% as agreed".

That incorporated an earlier adjustment in 1990 introducing a cap.

Discussions took place and the Appellant after considering the matters raised proposed a revised method by a letter dated 24 November 2000. The principal object was removing the cap and a further, refined, proposal from the Appellant was made by letter dated 7 February 2001. In the course of their correspondence the Appellant went no further than alluding to "the recoverable percentage of "grey area" residual input tax (i.e. input tax which has not been attributed under steps above)" and ultimately the PESM of 4 April 2001 was produced. It should be noted that there does not appear any sector or part of the residual tax specified in step 6 which is described as "disallowed".

Insofar as the word "disallowed" appears at step 3 and in the correspondence between the parties thereafter the Tribunal cannot attribute any meaning to that other than a convenient attribution of otherwise unallocated funds on which no recovery was thought possible.

Events thereafter

It did not take long for the Respondents to adopt the stance that what they had agreed appeared to give a larger recovery than they had anticipated, and that they thought, might not be fair or reasonable.

Having raised that matter with the Appellant Mr Melville's evidence was that he was not wholly surprised when the Appellant after undertaking a wide ranging and extensive review of how it accounted for VAT, reviewed its systems and attributions and discovered that there were matters which had erroneously been regarded as wholly exempt which were not, e.g. the foreign business of the Appellant and as a result produced the voluntary disclosures under scrutiny.

Those voluntary disclosures were calculated following the agreed and directed PESM employing a more detailed and correct attribution of residual tax.

The Respondents' Mr Melville startled Mr Tyre and surprised the Tribunal when he admitted that he had had no idea that the Appellant had foreign business. He would have had, had he fully reviewed the activities of the Appellant. However that ignorance does not have any relevance to the task of construing the words of the agreement. Having now understood that, the Respondents were bound to acknowledge that some form of adjustment of recoverable sums required to be made.

Their response to the voluntary disclosures was to argue that step 6 could not be applied since there was a gap in the attribution of supplies. The Respondent accepted that the input tax used to make specified supplies should be deductible according to use. They sought to arrange that outwith the Tribunal when the appeal was concluded, as they hoped in their favour.

The Respondents Contention

The Respondents contended that when construing the PESM taking into account its whole terms, it should be assessed against the measure of what is sensible within the overall objective of a fair and reasonable attribution of input tax. It was argued that the agreement must be construed according to the parties understanding at the time of how it would be implemented and supplemented by that understanding. So construed they said the method did not permit the approach of the Appellant. The formula does not it is said give a fair and reasonable recovery of input tax for the businesses involved. The Appellant now wishes to recover that which it previously did not. The method does not provide the means and to that extent there is a gap in the method for construction. The overriding objective of a fair and reasonable attribution must be applied rather than a literal interpretation of parts of a document.

The Appellant's Argument

In accordance with the ordinary principles of interpretation of commercial contracts an agreement is construed by considering the whole expressed terms of the contract and any admissible surrounding circumstances in order to ascertain what the words mean. The purpose of the agreement is part of a factual matrix against which it has to be construed – Reardon Smith Line Ltd v Hansen-Tangen [1976] 1WLR 989 per Lord Wilberfone at 995; Glasgow City Council v Caststop Ltd 2002 SLT47 at para 34. Further in interpreting a commercial document the Court should apply the commercially sensible construction of the condition in question Mannai Investment Co Ltd v Eagle Star Life Assurance Co Ltd [1997] AC749 per Lord Steyn at 771; Bank of Scotland v Dunedin Property Investment Co Ltd 1998 SC657 per Lord President at 661. Evidence of the parties subjective intention or of prior communings is admissible; Investors Compensation Scheme Ltd v West Bromwich Building Society [1998] 1WLR 896 per Lord Hoffman at 913 although prior communings may be admissible for the purpose of establishing the parties knowledge of the circumstances in which they use the word in the contract, Bank of Scotland v Dunedin Property Investment Co Ltd at 665.

The Appellant's argument was that the meaning of the words used was entirely clear. In step 6 the phrase "the balance of input tax" i.e. that not attributed by the preceding 5 paragraphs or steps is general and all encompassing and should not be read as restricted to the specific types of expenses areas mentioned at the end of the paragraph that does not define exclusively the balance of input tax. The commercial purpose of the agreement was to agree a PESM for an existing method which like the previous method attributed all input tax and not just some of it. The parties state of knowledge of the circumstances in which step 6 was agreed was that its purpose was to be all encompassing. That is also the commercially sensible construction and the intention of the parties could not have been that a gap should be created.

Interpretation and application of step 6

The Tribunal is clearly of the view that the words in step 6 were intended to and did encompass the entire balance of input tax not already attributed. The only strange feature is the use of the term "grey area" at the end since "grey area" was in fact historically the whole balance of un-attributed input tax. The Tribunal's view is that the inclusion of the words "grey area, Lothian Road, 1 George Street and staff ratio" do nothing to derogate from the balance of tax referred to in the opening phrase. They are illustrative only.

Disposal

The Tribunal accordingly allow the appeal to the extent of holding that the Appellant is right in its approach to the construction of the 4 April 2001 Agreement. It follows that the claimed refund of VAT in the voluntary disclosures are in principle payable. It was suggested that no contrary position to their being correct had been put forward to the Tribunal but the Tribunal think that would be going too far at this stage. The Respondents are entitled to verify the claims not only arithmetically but individually. The Tribunal accept that the Commissioners have been able to do so for many months now having had all the information supplied to them. The Tribunal accordingly continues the appeal to allow the Respondents a period of 6 months from the publication of this Decision to identify any areas of dispute and affords parties the opportunity if the question of what is due under the voluntary disclosure has not been agreed to return to the Tribunal for a determination.

We note for completeness that the Appellant presented an argument on the hypothesis that the Tribunal was against its submission and were to hold that there was a gap in the special method such that the input tax to which the voluntary disclosure related did not fall within any of the paragraphs. They submitted as follows:

"In absence of express agreement, regulation 103(1) would apply, and input tax would require to be attributed to taxable supplies to the extent that the inputs are used or to be used in making foreign and specified supplies expressed as a proportion of the whole use or intended use. This, however, would not or itself resolve the issue because it does not determine the method of attribution. A proxy for use must still be found. HMRC's submissions which were accepted by the Tribunal in Royal & Sun Alliance and in particular paragraph 56 in which it is explained that

"… Regulation 103 works by attributing out-of-country supplies expressly according to use, just as all other methods of attribution do in the UK. A trader typically proposes a value-based proxy from the variety of potential value-based proxies. If the Commissioners are satisfied that it results in a fair and reasonable attribution of out-of-country supplies, they will agree to its use".

Accepting that submission, the Tribunal held at paragraph 65 that as some mechanism had to be found whereby the attribution according to use is made, the Commissioners had power under the "care and management" provisions to conclude an agreement as to the manner of attributing residual input tax on out-of-country supplies based on use.

On the hypothesis upon which the Respondents' argument proceeds in the present case, there has been no such agreement. There remains the difficulty of deciding what proxy for "use" is to be applied. UK legislation has nothing helpful to say on this. The only possible answer, therefore, is that one is driven back to the default rule under the Sixth Directive, namely the turnover-based apportionment in the first subparagraph of Article 19.1.

It follows, therefore, that if the Respondents' argument that there is a gap in the Special Method were to be accepted, the Appellant would be entitled to recover the proportion of input tax falling into the gap which the total value of its "taxable" supplies (including foreign and specified supplies) bears to the total value of all of its supplies".

The Tribunal had it required to do so would have accepted that submission which was disputed by the Respondents and allowed an opportunity for amendment of the voluntary disclosure to reflect it.

Expenses

The Appellant has been successful in the proceedings before the Tribunal so far and is entitled to an award of expenses to date which failing agreement will require to be taxed in terms of the Tribunals Rules. The Tribunal makes that award.

T GORDON COUTTS, QC

CHAIRMAN

RELEASE: 28 SEPTEMBER 2007

EDN/07/05

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