The issue in these proceedings is whether the appellant, Airtours Holidays Transport Limited (formerly MyTravel Group plc) ("the appellant"), is entitled to recover (as input tax) value added tax ("VAT") charged by PricewaterhouseCoopers LLP ("PwC") in respect of certain services provided by PwC and for which the appellant paid. The resolution of the issue turns upon whether, for VAT purposes, PwC "supplied" services to the appellant. The services were provided in the context of a large-scale restructuring of the appellant, at a time when its business was in financial crisis.
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