- The Upper Tax Tribunal upheld the First Tier Tribunal’s decision in the JP Morgan Chase Bank case.
- The case involved intra-VAT group services and whether they were a single composite supply or separate supplies.
- Services included back-office, operational delivery, and trading infrastructure under a global master services agreement.
- VAT grouping legislation required VAT on intra-group supplies when resupplied by an overseas establishment.
- The Tribunal concluded there was a single supply subject to VAT, rejecting the VAT exemption argument.
- The case emphasized the importance of aligning intra-group contracts with operational reality.
- It highlighted the need for partially exempt VAT groups to regularly review intra-group supply arrangements.
Source: saffery.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.
