- Silverfleet Capital left Prudential VAT group in 2007
- Provided fund management services to Prudential’s with-profits funds
- Received performance-related fee in 2014 and 2015
- Question of whether VAT should be charged on the fee
- Court of Appeal agreed with HMRC that VAT should be charged
- Time of supply rules determine when VAT is due
- Silverfleet was no longer a VAT group member in 2014
- Appeal was dismissed
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.
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