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The Prudential Assurance Company Ltd v HMRC

Court of Appeal rules on intra-group VAT services and the time of supply

In The Prudential Assurance Company Ltd v HMRC [2024] EWCA Civ 300 (26 March 2024) the Court of Appeal (CA) decided by a majority of two to one that fees for investment management services performed while the supplier and the appellant had been members of the same VAT group were subject to VAT. This was because that the fees were not invoiced or paid for until after the supplier left the VAT group. Two out of the three judges decided that the court was not bound by its earlier decision in B J Rice & Associates v C&E Commrs [1996] STC 581 (B J Rice).

Under agreements for investment management services performed while the appellant and the supplier were members of the same VAT group the supplier was entitled to...

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