Mixed-use FinTech services not covered by the Investment Management Exemption

In BlackRock v HMRC (C-231/19), the CJEU held that management services provided by a financial technology services platform for the management of a mix of special investment funds and other investment funds could not benefit from the investment management exemption contained in Article 135(1)(g) of the Principal VAT Directive. Read more

Place of Supply AG Opinion

Advocate General Hogan has delivered his opinion in Wellcome Trust Ltd (C-459/19), setting out his view that a "taxable person" who receives services exclusively for the purposes of non-economic activities will nevertheless be treated as a "taxable person" for the purpose of determining the place of supply of those services (for VAT purposes). Read more

Post-Brexit Customs Regime

With a Brexit deal still out of reach, the UK government has introduced the Taxation (Cross-border Trade) Act 2018 setting out the customs regime for when the UK finally leaves the European Union.  We consider its provisions and explain how it fits in with wider legislation. Read more

VAT and defined benefit schemes: taxing times ahead

This article examines the merits of the current claims against HMRC for repayment of VAT charged on the supply of investment management services to defined benefit pension schemes, and how scheme sponsors might restructure their arrangements in order to secure recovery of VAT on those services (if the current claims against HMRC prove unsuccessful). Read more

Taxation of Restitution Interest Payments

This briefing considers the new 45% tax charge on awards of restitution interest paid by HMRC to companies in relation to claims for tax paid by mistake, introduced with effect from 21 October 2015. Read more