Recent decisions on intra-group VAT services, loan relationship debits and distributions from non-UK resident company are examined by Mike Lane and Zoe Andrews (Slaughter and May).
Prudential: interaction of VAT grouping and time of supply rules
Prudential v HMRC [2024] EWCA Civ 300 is about the interaction of the VAT grouping rules (VATA 1994 s 43) and the time of supply rules for continuous services (VAT Regulations SI 1995/2518 reg 90). The majority of the Court of Appeal (Lord Justice Newey and Lord Justice Underhill) dismissed the taxpayer’s appeal but there was a dissenting judgment by Lord Justice Nugee which may encourage a further appeal.
Silverfleet provided investment management services to Prudential whilst both were members of Prudential’s VAT group. Following a management buy-out Silverfleet later ceased to be a member of the VAT group. As part of the consideration for the investment management services...
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Recent decisions on intra-group VAT services, loan relationship debits and distributions from non-UK resident company are examined by Mike Lane and Zoe Andrews (Slaughter and May).
Prudential: interaction of VAT grouping and time of supply rules
Prudential v HMRC [2024] EWCA Civ 300 is about the interaction of the VAT grouping rules (VATA 1994 s 43) and the time of supply rules for continuous services (VAT Regulations SI 1995/2518 reg 90). The majority of the Court of Appeal (Lord Justice Newey and Lord Justice Underhill) dismissed the taxpayer’s appeal but there was a dissenting judgment by Lord Justice Nugee which may encourage a further appeal.
Silverfleet provided investment management services to Prudential whilst both were members of Prudential’s VAT group. Following a management buy-out Silverfleet later ceased to be a member of the VAT group. As part of the consideration for the investment management services...
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