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Single supply and VAT exemption for financial services: insights from JPMorgan

Naima Khalid (EY) and Anastasia Nourescu (Stewarts) consider the impact of the recent decision in JPMorgan.

VAT practitioners and in-house advisers at financial institutions await each development on the VAT exemptions for financial services with bated breath. Will this case be the one to clarify the scope of the exemptions? Unfortunately the answer to that is usually no.

The exemptions were introduced to simplify the taxation of financial services by avoiding the practical difficulties that arise in identifying the consideration for financial transactions. However simplification may seem an unlikely prospect in the context of an increasingly complex and international financial sector. The myriad of ways in which financial services are supplied and the intricate set-up of financial institutions mean that the application of the law can be very difficult to predict as it will entirely depend on a particular set of facts. This is perfectly exemplified...

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