- The Prudential Assurance Company Ltd CoA case involved issues regarding the relationship between VAT grouping rules and tax point legislation
- Silverfleet Capital provided investment management services to Pru while they were VAT grouped, but invoices were issued after Silverfleet left the group
- The First-tier Tribunal ruled in favor of Pru, but HMRC appealed to the Upper Tribunal which concluded that VAT was chargeable on the Performance Fees
- The UT considered that Silverfleet’s services were supplied when invoiced, after they left the VAT group, and therefore VAT was applicable
- Pru argued that Silverfleet should not be considered to have made the supply in the course of its business, but rather it should be assumed to have been carried on by Pru.
Source: deeksvat.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.
