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BlackRock: single supply, dual use – apportionment?

Etienne Wong (Old Square Chambers) examines the CJEU’s decision concerning VAT on a single supply of investment management services used to manage both special investment funds and non-SIFs.

BlackRock Investment Management (UK) Ltd (‘BlackRock’) manages investment funds. It uses services purchased from the US to do this namely an IT platform known as Aladdin.

Reverse charge

Where services are received from outside the UK the reverse charge under VATA 1994 s 8 is engaged. Under the reverse charge the recipient of the services (provided they are a business like BlackRock) is treated as both supplying and receiving the services (and as the deemed supplier it is required to account for VAT on them).

The reverse charge does not however apply where the services fall within one of the exemptions specified in VATA 1994 Sch 9. ...

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