ECJ Case C-231/19 (Blackrock Investment Management) – Comments – VAT treatment of management services

The UK court requested a preliminary ruling regarding the interpretation of the VAT exemption for the management of Special Investment Funds (‘SIFs’). This case concerns Blackrock Investment Management (UK) (no. C-231/19).

A third party supplies a management service to a fund manager and which is used by that fund manager for both the management of SIFs (VAT exempt) and the management of non-SIFs (subject to VAT). The questions are as follows:

• Is this a single supply to be subject to a single rate of tax; and if so, how is that single rate to be determined; or
• Is the consideration for that single supply to be apportioned, so as to treat part of the single supply as VAT exempt and part as VAT taxable?

Source KPMG

---

---