This appeal by American Express Services Europe Limited (AESEL) concerned the place of supply of VAT exempt payment services. AESEL believed it made its supplies to TRSCo, a company established outside the EU. By virtue of The Specified Supplies Order 1999, AESEL could recover input VAT on costs relating to the supplies made to TRSCo. HMRC argued that AESEL actually made its supplies to AESPL, a company established within the EU; supplies of VAT exempt payment services between AESEL and AESPL would not give a right to input VAT recovery for AESEL.
Source: constablevat.com
