Businesses and their advisers should consider the potential implications for VAT treatments on the provision of technology platforms following the UT decision in BlackRock, write Peter Dylewski and Sarah Daley (KPMG).
In the recent case of BlackRock Investment Management (UK) Ltd v HMRC [2018] UKUT 415 a US company provided the service of the use and functionality of the Aladdin investment management platform to a group company in the UK. The UK entity used this Aladdin service partly for managing VAT exempt funds (SIFs) and for the most part for managing taxable non SIFs. The VAT dispute essentially concerned whether and to what extent the UK company should account for VAT under the reverse charge mechanism on the fees paid for this service.
It was agreed between the parties that there was a single supply of the platform in this case and that the non-SIF usage constituted the predominant element....
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Businesses and their advisers should consider the potential implications for VAT treatments on the provision of technology platforms following the UT decision in BlackRock, write Peter Dylewski and Sarah Daley (KPMG).
In the recent case of BlackRock Investment Management (UK) Ltd v HMRC [2018] UKUT 415 a US company provided the service of the use and functionality of the Aladdin investment management platform to a group company in the UK. The UK entity used this Aladdin service partly for managing VAT exempt funds (SIFs) and for the most part for managing taxable non SIFs. The VAT dispute essentially concerned whether and to what extent the UK company should account for VAT under the reverse charge mechanism on the fees paid for this service.
It was agreed between the parties that there was a single supply of the platform in this case and that the non-SIF usage constituted the predominant element....
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