Victoria Oil & Gas plc v The Commissioners for HMRC

Decision date: 26 August 2026

Neutral citation: [2026] UKFTT 1246 (TC)

Overall AI summary confidence: high

AI Notice: Any short overview, ratio decidendi summary or obiter dicta summary shown on this page is AI-generated, provided only to help users assess potential relevance more quickly, and may be wholly inaccurate. No liability is accepted for the accuracy of any such summary, regardless of any AI confidence rating shown. Users should check the underlying decision and obtain appropriate legal advice rather than relying on any summary.

Short overview

This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.

AI confidence in this short overview: high

This appeal concerned HMRC best-judgment VAT assessments of £884,049 against Victoria Oil & Gas plc (VOG) for 2019–2022 and whether those assessments were properly made and whether disputed input VAT was directly and immediately linked to taxable supplies to Gaz du Cameroun (GdC). The Tribunal held HMRC acted to the best of its judgment and allowed recovery of input VAT on costs recharged or directly attributable to GdC (including certain litigation/dispute costs) but disallowed recovery for Therium-funded Kermerkol items and general head office and corporate legal costs. VOG was not a wholly taxable business and therefore not entitled to recover all input VAT; the appeal was allowed in part.

Ratio decidendi

This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.

AI confidence in this ratio decidendi summary: medium

A best-judgment assessment is valid where the officer honestly and reasonably applies judgment to the material available at the time and is not required to carry out exhaustive reconstruction of taxpayer records; input VAT is recoverable when costs are incurred as cost components of remunerated management services to a subsidiary and there is evidence of recharge or direct attribution to taxable supplies.

Obiter dicta

This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.

AI confidence in this obiter dicta summary: medium

The Tribunal indicated that later-supplied evidence does not by itself demonstrate that an earlier best-judgment assessment was unreasonable, and that delay in recharging costs (for example pending litigation outcomes) does not necessarily sever a direct and immediate link where the costs were incurred for managing the subsidiary’s business.