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Tax and the City review for September 2021

This month’s review by Mike Lane and Zoe Andrews (Slaughter and May).

Target Group: outsourced loan administration services not within financial services exemption

The Court of Appeal in Target Group Ltd v HMRC [2021] EWCA Civ 1043 considered the application of the financial services exemption from VAT to outsourced loan administration services including the operation of loan accounts and payment processing. This case illustrates how difficult it is in light of developments in CJEU jurisprudence for a loan service provider supplying outsourced functions to a bank after the bank had originated the loan to show these supplies should be exempt. The Court of Appeal unanimously agreed with the Upper Tribunal (UT) that recent CJEU case law has effectively overturned earlier Court of Appeal judgments in this area such that the VAT exemption did not apply because the services supplied by Target are not ‘transactions...

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