Upper Tax Tribunal Dismisses JP Morgan’s Appeal on VAT Liability of Intra-Group Services

• The Upper Tax Tribunal dismissed JP Morgan Chase Bank’s appeal on 16 June 2025.
• The decision confirmed HMRC’s stance on VAT liability for intra-group services within a UK VAT group.
• Services provided within the group are considered a single, composite taxable supply.
• The VAT financial exemption did not apply to the supplies in question.
• JP Morgan argued unsuccessfully for the exemption for some supplies if examined separately.
• The appeal followed a September 2023 First Tier Tribunal case supporting HMRC’s view.
• The dispute involved services from JP Morgan Chase Bank to JP Morgan Securities plc within the same VAT group.
• The case focused on bought-in services from outside the group used for partly exempt UK group members.
• A further appeal to the Court of Appeal is likely as JP Morgan may find the exemption interpretation too narrow.

Source: vatcalc.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.