Hui Ling McCarthy KC and Michael Ripley (11 New Square) examine the much-awaited Supreme Court judgment on the VAT liability of loan administration services.
The VAT exemption for ‘transactions including negotiation concerning ... payments transfers debts’ (currently found in article 135(1)(d) of the Principal VAT Directive) has been a fertile area for disputes for decades. Businesses hoping to rely on the exemption are typically supplying their services to either a partly-exempt financial institution or a consumer. In either case a VAT charge is likely to be a significant burden potentially affecting the viability of the business model. At a time when the market for payment service providers is diversifying the Supreme Court’s judgment in Target Group Ltd v HMRC [2023] UKSC 35 is a timely reminder of the evolution of the case law.
Development of the case law
The first CJEU judgment to...
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Hui Ling McCarthy KC and Michael Ripley (11 New Square) examine the much-awaited Supreme Court judgment on the VAT liability of loan administration services.
The VAT exemption for ‘transactions including negotiation concerning ... payments transfers debts’ (currently found in article 135(1)(d) of the Principal VAT Directive) has been a fertile area for disputes for decades. Businesses hoping to rely on the exemption are typically supplying their services to either a partly-exempt financial institution or a consumer. In either case a VAT charge is likely to be a significant burden potentially affecting the viability of the business model. At a time when the market for payment service providers is diversifying the Supreme Court’s judgment in Target Group Ltd v HMRC [2023] UKSC 35 is a timely reminder of the evolution of the case law.
Development of the case law
The first CJEU judgment to...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
