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Place of Supply Reversal

 
Nick Warner Director of VAT at PKF outlines the Zurich Insurance Company case. Nick was previously Head of Indirect Taxes at Zurich Insurance Company
 
It's all change in a recent court case that went back to basics to determine that consulting services are supplied where they are enjoyed. Are we now more confused than ever? The High Court has upheld the appeal of HM Revenue & Customs (HMRC) in overturning the decision of the Tribunal (VTD 19157). The Tribunal had decided that the so-called 'calling the shots' factor was the most influential in deciding the place of supply of Sixth Directive Article 9.2(e) services in a scenario where a company had established its business in one jurisdiction and had one or more fixed establishments in others.
 
In an interesting decision ...

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