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