- Risk of Exceeding Exemptions: The complexity and broad scope of outsourced services, such as those in the JPMorgan Chase case in the UK, increase the likelihood that they may exceed the boundaries of available exemptions or reduced tax rates.
- Single Supply Concept: The Upper Tribunal’s reasoning suggests that an entire outsourced back office function should be viewed as a single supply, highlighting the challenges of coordinating services from multiple non-connected providers to meet various economic demands.
- Taxable Elements and Exemptions: While the Tribunal concluded that the Business Delivery Services contained no exempt elements, there are plausible taxable components, such as risk assessments, indicating that some aspects may impact legal and financial positions beyond mere contractual rights.
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