Matrix Securities Ltd v HMRC

In Matrix Securities Ltd v HMRC (TC02006 – 1 June) a UK company (S) supplied management and consultancy services to a company (T) which was resident in the Republic of Ireland. HMRC issued an assessment charging tax on the supplies. S appealed contending that the supplies were within VATA 1994 Sch 5 para 3 so that the place of supply was in the Republic of Ireland. The First-tier Tribunal accepted this contention and allowed the appeal finding that the supplies comprised ‘sophisticated accounting analyses and cash-flow forecasts for large-scale projects’.

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Why it matters: VATA 1994 Sch 5 para 3 (which was repealed from January 2010) provided that ‘services of consultants engineers consultancy bureaux lawyers accountants and other similar services’ were supplied where they were received. The First-tier Tribunal accepted the company’s contention that the services here were...