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.

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.