In Wheels Common Investment Fund Trustees Ltd v HMRC (CJEU Case C-424/11) a company (C) provided fund management services to several companies which administered defined-benefit occupational pension schemes. C accounted for VAT on its supplies on the basis that the recipients did not qualify for exemption under VATA 1994 Sch 9 Group 5. Following the CJEU decision in JP Morgan Fleming Claverhouse Investment Trust PLC v HMRC [2008] STC 1180 C submitted a repayment claim contending that its supplies qualified for exemption under EC law. HMRC rejected the claim. The recipient companies appealed to the FTT contending that they qualified as ‘special investment funds’ within article 135(1)(g) of EC Directive 2006/112/EC. The tribunal referred the case to the CJEU for a...
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In Wheels Common Investment Fund Trustees Ltd v HMRC (CJEU Case C-424/11) a company (C) provided fund management services to several companies which administered defined-benefit occupational pension schemes. C accounted for VAT on its supplies on the basis that the recipients did not qualify for exemption under VATA 1994 Sch 9 Group 5. Following the CJEU decision in JP Morgan Fleming Claverhouse Investment Trust PLC v HMRC [2008] STC 1180 C submitted a repayment claim contending that its supplies qualified for exemption under EC law. HMRC rejected the claim. The recipient companies appealed to the FTT contending that they qualified as ‘special investment funds’ within article 135(1)(g) of EC Directive 2006/112/EC. The tribunal referred the case to the CJEU for a...
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