Glint Pay Services Ltd (Glint) operated an app and payment card interface enabling its clients (members of the public) to buy gold from it and sell gold to it – in effect, using the gold as money via the app and debit card. Glint maintained that it had a legitimate expectation based on the content of a memorandum of understanding between the LBMA and another precious metals market and HMRC (the MOU) that its supplies should be zero-rated. The Court was of the view that the intention behind the MOU was for zero-rating to apply to dealings on the London wholesale markets, and not to retail sales, such as those carried out by Glint.
Source: rpc.co.uk