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Do VAT groups need agreements?

The white paper on banking reform published earlier this month may seem like an odd place to start in an article about VAT groups but it is surprisingly relevant. Paragraphs 2.75 and 2.76 summarise the government’s views in relation to consultation question 9. That question has three parts:

  • What are your views on possible approaches to mitigate the risk of a ring-fenced bank being jointly and severally liable for VAT obligations of its wider corporate group?
  • What is the potential impact of ring-fencing on banks’ carried-forward losses?
  • Are there other intra-group tax exposures that could affect the ring-fenced bank or other tax issues arising from the creation of the ring-fence?

The white paper expresses the views that ‘The tax liabilities of banks should neither give rise to contagion which could potentially be transmitted to ring-fenced banks nor impede...

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