VAT Exemption Denied: FTT Rules Intra-Group Services as Single Supply

• JPMorgan Chase Bank NA made supplies to JPMorgan Securities plc
• Supplies included generic business services and services necessary for transactions with clients
• HMRC contended that the supplies were taxable
• FTT determined that the supplies constituted a single supply
• FTT concluded that the single supply was taxable and not exempt from VAT
• FTT did not make a finding on the Exemption Issue
• CBNA argued that the securities exemption and payment exemption applied
• FTT concluded that the transactions were technical or administrative in nature and not exempt
• Case provides guidance on determining single or multiple supplies
• VAT grouping does not mean all transactions are disregarded for VAT purposes.

Source: rpc.co.uk

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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