Market leading insight for tax experts
View online issue

CCLA Investment Management Ltd v HMRC

Fund management exemption.

In CCLA Investment Management Ltd v HMRC [2024] UKFTT 636 (TC) (15 July) the First-tier Tribunal (FTT) held that fund management services supplied by an investment manager to six Charities Official Investment Funds (COIFs) were exempt from July 2014 onwards. However  services provided to two other categories of fund failed to qualify for exemption. 

CCLA provided fund management services to investment funds whose investors were charities Church of England entities and local authorities. These services had historically been treated as taxable but the taxpayer decided that they should have been treated as exempt and submitted several claims for overdeclared output VAT. 

The appeal concerned 13 funds which could be split into three categories namely: 

  • six COIFs;
  • six Church of England Central Board of Finance (CBF) Funds; and
  • one Local Authorities’ Property Fund (LAPF).

The fund management rules considered were those that applied before the end of the Brexit transition period...

If you or your firm subscribes to Taxjournal.com, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
EDITOR'S PICKstar
Top