The taxpayer, emerchantpay Ltd (“EMPL”) and emerchant OOD (“EMPO”) are in the same corporate group, the eMerchantPay Group (“the Group”). EMPO is a Bulgarian company and EMPL is incorporated and resident, for tax purposes, in the UK.
EMPO makes supplies to EMPL. The taxpayer sought a ruling from HMRC who were of the view that the supplies were taxable. The taxpayer contends that EMPO is essentially providing financial intermediation services to EMPL which are exempt under Item 5, Group 5 of Schedule 9 to VATA 1994 (and therefore no reverse charge due).
Source KPMG
ECJ Cases referred to:
Latest Posts in "United Kingdom"
- Boehringer Ingelheim Ltd – Upper Tribunal Rules Against Taxpayer on Price Control Payments Reducing VATable Consideration
- Colchester Institute Corporation (No. 2) – Court of Appeal Upholds Taxpayer Win on Grant Income as Consideration for Education
- HMRC Updates VAT Guidance for Charities, Adds New Relief for Donated Goods from April 2026
- HMRC Issues New Guidance on Option to Tax Property When Cancelling VAT Registration
- Isle of Man Raises Late Payment Interest Rate on VAT to Align with UK from May 2026
