Hippodrome Casino Ltd (appellant) v HM Revenue and Customs (respondent)

Tuesday 24 – Wednesday 25 June 2025

By Appellant’s Notice filed on 1 April 2024, the Appellant Hippodrome Casino Ltd (“HCL”) appeal the decision of the Upper Tribunal (Tax and Chancery Chamber) (“UT”), judgment being delivered on 29 January 2024.

The initial appeal concerned the method for the recovery of residual input tax during the period from 2012-13 to 2017-18 (inclusive) by the appellant, HCL, which makes taxable supplies of hospitality and entertainment and exempt gaming supplies from its premises.

The First Tier Tribunal concluded that HCL’s means of apportioning and recovering input VAT on HCL’s overhead expenditure by reference to floorspace more accurately reflected the economic use of that expenditure than the standard turnover-based method of recovery provided by the VAT Regulations and allowed HCL’s appeals.

The Upper Tribunal allowed HMRC’s appeal holding that the taxpayer’s partial exemption override based on floor space did not guarantee a more precise calculation of recoverable VAT than the standard method.

Lower Court Judgment

Appellant Skeleton Argument

Respondent Skeleton Argument

View hearing:

Day 1

Part 1

Part 2

Day 2

Part 1

Part 2