The Tax Tribunal: a beautifully 'choreographed' TOGC

On 15 January 2008, the Royal College of Paediatricians and Child Health completed the purchase of a freehold building in central London from Coleridge (Theobalds Road) Ltd for £17,445,000.

Prior to this transfer, Coleridge had made an option to tax in relation to the property and so (in the absence of TOGC treatment) a significant VAT charge would arise, which would be largely irrecoverable in the hands of the college because of its exempt and non-business activities.

Accordingly, the parties sought tax advice to try to achieve a VAT-efficient structure…

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