- UK Funerals On-Line Ltd (UKFO) provides repatriation services for deceased persons from the UK to other countries.
- The company argues that its services are zero-rated international transport, as they only transport the body and have no involvement in the funeral arrangements.
- HMRC argues that the services are exempt under item 2 of Group 8 of Schedule 9 to VATA 1994, which exempts “The making of arrangements for or in connection with the disposal of the remains of the dead.”
- The First-tier Tribunal (FTT) found that UKFO’s services lead directly to the disposal of remains and are connected with arrangements for disposal, falling within the exemption.
- However, the FTT also found that the predominant element of UKFO’s supplies is transport, which would be zero-rated.
Source KPMG
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