- HMRC’s new GfC 20 sets out its approach to VAT on outsourced fund management services, focusing on whether the services are a single supply or multiple supplies.
- VAT exemption applies only if the fund is a qualifying fund under Group 5, Schedule 9 VATA 1994 and the services are supplied solely to that qualifying fund.
- HMRC says the services must, viewed broadly, form a distinct whole that is specific to and essential for management of the qualifying fund.
- A single contract is not decisive; HMRC will look at whether the services under a master services agreement are, in substance, a single indivisible supply or multiple supplies, using indicators such as separate suppliers, the typical consumer’s view, contractual terms and economic reality, and legislative intent.
- Businesses can contact HMRC about the guidance or correct prior VAT returns if they believe they have applied VAT incorrectly.
Source: icaew.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.
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