- JPMorgan Chase NA provided services to JPMorgan Securities plc under an intercompany contract.
- Services included business delivery services related to trading infrastructure and support services like HR and legal.
- HMRC viewed the services as a single taxable supply.
- CBNA argued for separate supplies, with support services being taxable and BDS being VAT exempt.
- The First-tier Tribunal found all contract elements formed a single taxable supply.
- The Upper Tribunal upheld the decision, confirming a single taxable supply.
- The UT agreed that contracts reflected the economic reality between parties.
- The UT applied a narrow interpretation of exemptions, as set by the Supreme Court.
- The securities exemption did not apply to CBNA’s services.
- The UT dismissed CBNA’s appeal.
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.
