- UK branch of overseas company not qualified as member of VAT group in UK
- Being part of VAT group allows for reduced VAT costs
- BSC UK proposed to be established for efficiency in providing services to Barclays Group UK businesses
- If BSC UK joined VAT group, savings of £15m-20m per annum for Barclays group
- HMRC refused grouping application due to lack of fixed establishment in UK
- FTT considered definition of fixed establishment as having sufficient permanence and resources
- BSC UK had no human or technical resources available at time of application
Source: cadwalader.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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