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The BlackRock VAT case: An Impossible Combination of Artificial Intelligence and the VAT Exemption?

BlackRock Investment Management (UK) Ltd (“BlackRock”) was a company responsible for the management of funds: mainly non-special investment funds (“non-SIFs”), but also special investment funds (“SIFs”). In this context, BlackRock used the services of BlackRock Financial Management Inc. in the US (“BFMI”) through an IT platform. These services spanned the entire investment cycle (performance and risk analysis as well as monitoring to enable the portfolio managers to make investment and trading decisions, alongside the monitoring of regulatory compliance). UK VAT was self-assessed on the full remuneration paid to BFMI.

As this outcome may have a direct impact on Luxembourg fund managers and their relations with third-party suppliers, it is advisable to review existing structuring in light of the above judgment.

Source: theworldlawgroup.com

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