BLP Group Plc v C & E Commissioners

CJEC Case C-4/94; [1995] STC 424; [1995] 1 ECR 983; [1996] 1 WLR 174; [1995] All ER (EC) 401

This case established the principle that where there is a direct and immediate link of an expense that cannot be ignored and looked beyond. BLP Group Plc (BLP) sold its subsidiary to raise money for its taxable business, i.e. raising cash. Even though the purpose was to assist making taxable supplies in the future, it cannot be ignored that essentially this was a sale of shares, an exempt activity and the attributable input tax was disallowed.