Natasha was instructed by HMRC in this complex partial exemption dispute between HMRC and N Brown, a FTSE 250 company with £900 million annual turnover.

N Brown challenged historic assessments totalling £42 million with future assessments of approximately £10 million per annum at stake. A three-week trial took place to determine the extent to which NB could recover VAT incurred on marketing costs. N Brown argued that it was entitled to recover VAT on the vast majority of its marketing costs since they mainly related to the sale of goods. HMRC said a substantially higher proportion of VAT could not be recovered because the marketing expenses related to both the taxable sale of goods and the exempt supply of financial services.

The FtT found for HMRC. Natasha was led in this matter by Hui Ling McCarthy QC.