- The Prudential Assurance Company Ltd CoA case involved questions about VAT grouping rules and time of supply legislation
- Silverfleet Capital provided investment management services to Pru while they were in a VAT group
- After Silverfleet left the VAT group, they invoiced Pru for performance fees plus VAT
- The First-tier Tribunal ruled in favor of Pru, but HMRC appealed to the Upper Tribunal which ruled that VAT was chargeable on the fees
- The Upper Tribunal considered that services were supplied when invoiced, not when provided while in the VAT group
- Pru argued that Silverfleet did not make the supply in the course of any business carried on by it.
Source: marcusward.co
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.
