In Clydesdale v HMRC [2019] UKFTT 419 (26 June 2019) the FTT found that the re-issue of banknotes by a bank is a standard-rated supply.
Clydesdale is an issuing bank; a bank authorised to issue banknotes under the Banking Act 2009. The appeal concerned banknotes issued by Clydesdale. These are banknotes in relation to which Clydesdale promises to pay the bearer on demand the amount stated on the face of the note. This entails an obligation to hold backing assets.
The issue of new banknotes is a standard-rated supply under VATA 1994 Sch 8 group 11 item 1. Banks issuing bank notes are therefore able to recover the related input tax. Where the banknote is being issued for a subsequent time that process involves the receipt of the banknote whether directly from a customer or from another bank which has received the banknote from its bearer and...
