Supply of intra-group services was a single composite taxable supply
In JPMorgan Chase Bank NA v HMRC [2025] UKUT 188 (TCC) (16 June) the UT dismissed the company’s appeal and upheld the FTT decision that the supply of intra-group services was a single composite taxable supply and the exemption for financial services did not apply.
The main issue under appeal was the VAT treatment of services supplied from JPMorgan Chase Bank NA (CBNA) to JPMorgan Securities plc (SPLC). These two entities were VAT grouped so although such supplies would normally be disregarded for VAT purposes this was not the case here as the services were ‘bought-in’ services and subject to anti-avoidance provisions under VATA 1994 s 43(2A) (2B).
The appeal assessed two issues; firstly were the services from CBNA to SPLC a single or multiple supply and secondly what VAT rate...
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Supply of intra-group services was a single composite taxable supply
In JPMorgan Chase Bank NA v HMRC [2025] UKUT 188 (TCC) (16 June) the UT dismissed the company’s appeal and upheld the FTT decision that the supply of intra-group services was a single composite taxable supply and the exemption for financial services did not apply.
The main issue under appeal was the VAT treatment of services supplied from JPMorgan Chase Bank NA (CBNA) to JPMorgan Securities plc (SPLC). These two entities were VAT grouped so although such supplies would normally be disregarded for VAT purposes this was not the case here as the services were ‘bought-in’ services and subject to anti-avoidance provisions under VATA 1994 s 43(2A) (2B).
The appeal assessed two issues; firstly were the services from CBNA to SPLC a single or multiple supply and secondly what VAT rate...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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