- JPMorgan Chase Bank, NA supplied services to JPMorgan Securities plc under intra-group contracts
- The First-tier Tribunal determined that CBNA was providing single supplies of VATable services
- The FTT concluded that all the elements supplied worked together to provide everything SPLC needs for regulatory compliant trading
- It would be artificial to split the different elements of the supply
- The purpose of CBNA making the overall supply was to ensure standardization of trading services between subsidiaries
- The FTT concluded that all the elements formed a single supply
- The FTT could not identify a predominant or principal element
- The supply had to be taxable.
Source: taxscape.deloitte.com
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
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