§ Janet Anderson
[holding answer 14 March 2001]In seeking to recognise the charitable status of the Hinduja Foundation, the New Millennium Experience Company (NMEC) sought the advice of its tax consultants, PricewaterhouseCoopers (PwC). NMEC passed on to Mr. S. P. Hinduja's office advice it received from PwC in December 1998 on the normal basis in such circumstances that neither NMEC nor PwC were liable or responsible for any reliance the Hindujas placed on that advice. In essence the advice indicated that if the terms of the Hinduja Foundation's contribution mirrored that of the sponsorship agreements drawn -up for commercial sponsors of the Dome then VAT would apply. In early February 1999 NMEC submitted to the Hinduja Foundation a donor agreement that mirrored agreements drawn-up for the other charitable trusts contributing to the faith zone. At that time the donation was not liable for VAT.