Target Group, Vermilion and changes to HMRC’s guidance on the double tax treaty passport scheme are among the developments examined by Mike Lane and Zoe Andrews (Slaughter and May).
Target Group: outsourced loan administration services not within financial services exemption
The Supreme Court in Target Group Ltd v HMRC [2023] UKSC 35 considered the application of the financial services exemption from VAT under article 135(1)(d) of the Principal VAT Directive to outsourced loan administration services including the operation of loan accounts and payment processing and unanimously concluded that the services did not fall within the exemption.
In order for the financial services exemption to apply the services must have the effect of transferring funds and changing the legal and financial situation of the relevant parties. The taxpayer and HMRC disagreed on the proper interpretation of the case law as to whether causal effect was sufficient for...
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Target Group, Vermilion and changes to HMRC’s guidance on the double tax treaty passport scheme are among the developments examined by Mike Lane and Zoe Andrews (Slaughter and May).
Target Group: outsourced loan administration services not within financial services exemption
The Supreme Court in Target Group Ltd v HMRC [2023] UKSC 35 considered the application of the financial services exemption from VAT under article 135(1)(d) of the Principal VAT Directive to outsourced loan administration services including the operation of loan accounts and payment processing and unanimously concluded that the services did not fall within the exemption.
In order for the financial services exemption to apply the services must have the effect of transferring funds and changing the legal and financial situation of the relevant parties. The taxpayer and HMRC disagreed on the proper interpretation of the case law as to whether causal effect was sufficient for...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
