VAT Groups and Tax Points: The Prudential Assurance Co. Ltd CoA Case Analysis

• The Prudential Assurance Company Ltd CoA case involved questions about VAT grouping rules and time of supply legislation
• Silverfleet Capital provided investment management services to Pru while they were in a VAT group
• After Silverfleet left the VAT group, they invoiced Pru for performance fees plus VAT
• The First-tier Tribunal ruled in favor of Pru, but HMRC appealed to the Upper Tribunal which ruled that VAT was chargeable on the fees
• The Upper Tribunal considered that services were supplied when invoiced, not when provided while in the VAT group
• Pru argued that Silverfleet did not make the supply in the course of any business carried on by it.

Source: marcusward.co

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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