Services supplied within an investment banking group were a single supply subject to VAT
In JPMorgan Chase Bank NA v HMRC[2023] UKFTT 856 (TC) the First-tier Tribunal (FTT) held that certain services supplied within a large corporate banking group constituted a single supply of services and that single service did not qualify for the VAT exemption.
JPMorgan Chase Bank NA (CBNA) supplied services to JPMorgan Securities plc (SPLC) and it was these services which formed the basis of the appeal. It is worth noting that although CBNA and SPLC were members of the same VAT group and therefore supplies from one to the other would ordinarily be disregarded as CBNA bought in services from overseas in order to enable it to make the intragroup supplies HMRC contended that the intra-group supplies were taxable pursuant to VATA 1994 s 43(2A) and (2B).
The appeal...
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Services supplied within an investment banking group were a single supply subject to VAT
In JPMorgan Chase Bank NA v HMRC[2023] UKFTT 856 (TC) the First-tier Tribunal (FTT) held that certain services supplied within a large corporate banking group constituted a single supply of services and that single service did not qualify for the VAT exemption.
JPMorgan Chase Bank NA (CBNA) supplied services to JPMorgan Securities plc (SPLC) and it was these services which formed the basis of the appeal. It is worth noting that although CBNA and SPLC were members of the same VAT group and therefore supplies from one to the other would ordinarily be disregarded as CBNA bought in services from overseas in order to enable it to make the intragroup supplies HMRC contended that the intra-group supplies were taxable pursuant to VATA 1994 s 43(2A) and (2B).
The appeal...
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