Introduction: Background: the scope of VAT
Normally, by virtue of s4(1) VAT Act 1994, VAT is chargeable on any supply of goods or services made by a taxable person in the course or furtherance of his business, provided it is a taxable supply. However a transaction will not be a supply for VAT purposes if:
- there is no consideration (unless there is a deemed supply);
- it is within the same legal entity; or
- there is a specific exclusion in the legislation.
The last includes the supply of assets in the Transfer of a business as a Going Concern (TOGC).