The Upper Tribunal’s decision has complicated the position regarding the taxation of loyalty rewards, writes Sarah Lane (Burges Salmon).
The tax treatment of loyalty schemes has been complicated further by the Upper Tribunal’s judgment in HMRC v Hargreaves Lansdown Asset Management [2019] UKUT 246.
The key facts in Hargreaves
The Financial Conduct Authority (FCA) in 2014 had made changes in the rules applicable to commission to create a transparent charging structure as part of its retail distribution review. This case concerned both the pre-April 2014 arrangements applied by Hargreaves Lansdown (HL) and its post-April 2014 arrangements which were changed following the review.
The First-tier Tribunal (FTT) ([2018] UKFTT 127) had found as facts that before April 2014:
HL benefited customers investing through its platform by negotiating lower annual management charges with fund managers;
the difference between this lower rate and the...
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The Upper Tribunal’s decision has complicated the position regarding the taxation of loyalty rewards, writes Sarah Lane (Burges Salmon).
The tax treatment of loyalty schemes has been complicated further by the Upper Tribunal’s judgment in HMRC v Hargreaves Lansdown Asset Management [2019] UKUT 246.
The key facts in Hargreaves
The Financial Conduct Authority (FCA) in 2014 had made changes in the rules applicable to commission to create a transparent charging structure as part of its retail distribution review. This case concerned both the pre-April 2014 arrangements applied by Hargreaves Lansdown (HL) and its post-April 2014 arrangements which were changed following the review.
The First-tier Tribunal (FTT) ([2018] UKFTT 127) had found as facts that before April 2014:
HL benefited customers investing through its platform by negotiating lower annual management charges with fund managers;
the difference between this lower rate and the...
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:
