Supreme Court Upholds VAT Charges on Intra-Group Services Post-Group Exit in Prudential Case

• Supreme Court ruled in favor of HMRC in Prudential Assurance Company Ltd v HMRC on 11 September 2025
• Case impacts VAT treatment of intra group supplies and VAT grouping rules
• Dispute involved investment management services between Silverfleet Capital Ltd and Prudential Assurance Company Ltd
• Both entities were in the same VAT group when services were performed
• Payments were invoiced and paid after Silverfleet Capital Ltd left the VAT group
• HMRC argued VAT was chargeable based on timing of invoice or payment
• Court of Appeal supported HMRC’s position, stating VAT was due
• Supreme Court upheld the Court of Appeal’s ruling
• Businesses may face VAT charges on intra group services due to timing of invoicing or payment
• Ruling affects large corporate and financial institutions with intra group service arrangements
• Raises questions about VAT group protection when corporate structures change
• Impacts financial services sector and businesses using VAT grouping to avoid irrecoverable VAT costs

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.

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