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
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