No VAT Exemption for Intra-Group Supplies, Says JPMorgan Chase Bank Case

• JPMorgan Chase Bank NA v HMRC case found that support and business services supplies were one single supply not exempt from VAT.
• The intra-group supply exemption was disapplied due to elements coming from overseas.
• CBNA supplied support services and business delivery services to SPLC.
• The services were dealt with under a master services agreement and billed in a lump sum.
• CBNA provided all of these services to group affiliates.
• SPLC would not have been able to decline any of the services.
• CBNA bought overseas services in order to make supplies to SPLC.
• HMRC argued that this disapplied the intra-group exemption.
• CBNA accepted that the support services were subject to VAT.
• The FTT found that all elements of the supply were closely linked and not available separately.
• The FTT decided that there was one single supply of services that was not exempt as a supply of financial services.

Source: rossmartin.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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