Bryn Reynolds and Gary Barnett (Simmons & Simmons) provide your monthly review of the VAT developments that matter.
Economic reality and identifying the recipient of a supply
In American Express Services Europe Limited v HMRC [2019] UKFTT 548 the FTT has held that the recipient of supplies from a UK card issuer was the contractual recipient where the economic and commercial reality of intra-group payment arrangements did not indicate otherwise. This was despite disparity in the pricing for the supplies when re-charged and the intra-group settlement arrangements.
The appellant (AESEL) was a member of the Amex group issuing Amex cards to customers. As card issuer it supplied VAT exempt payment services. AESEL submitted a claim to recover the input tax on those supplies as they were ‘specified supplies’ with an entitlement to input tax recovery. HMRC rejected the claim...
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Bryn Reynolds and Gary Barnett (Simmons & Simmons) provide your monthly review of the VAT developments that matter.
Economic reality and identifying the recipient of a supply
In American Express Services Europe Limited v HMRC [2019] UKFTT 548 the FTT has held that the recipient of supplies from a UK card issuer was the contractual recipient where the economic and commercial reality of intra-group payment arrangements did not indicate otherwise. This was despite disparity in the pricing for the supplies when re-charged and the intra-group settlement arrangements.
The appellant (AESEL) was a member of the Amex group issuing Amex cards to customers. As card issuer it supplied VAT exempt payment services. AESEL submitted a claim to recover the input tax on those supplies as they were ‘specified supplies’ with an entitlement to input tax recovery. HMRC rejected the claim...
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:
