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Holding companies, VAT groups and funds

VAT cases on investment funds are invariably interesting, and the latest one - Melford Capital - is no exception, writes Etienne Wong (Old Square Tax Chambers).

VAT cases on investment funds are few (but not quite far between). And when one comes along it usually comes with a note or two of interest. The latest – Melford Capital [2020] UKFTT 6 (TC) – is no exception.

Investment funds: an overview

The big gun in investment management is (perhaps not surprisingly) the manager – the person with the investment expertise. Typically the manager creates its own client – the fund.

The fund is the vehicle through which funds from third party investors are pooled and invested (in accordance with the manager’s advice) in assets that are then managed by the manager. The fund is often constituted as...

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