- JPMorgan Chase Bank NA made supplies to JPMorgan Securities plc
- Supplies included generic business services and services necessary for transactions with clients
- HMRC contended that the supplies were taxable
- FTT determined that the supplies constituted a single supply
- FTT concluded that the single supply was taxable and not exempt from VAT
- FTT did not make a finding on the Exemption Issue
- CBNA argued that the securities exemption and payment exemption applied
- FTT concluded that the transactions were technical or administrative in nature and not exempt
- Case provides guidance on determining single or multiple supplies
- VAT grouping does not mean all transactions are disregarded for VAT purposes.
Source: rpc.co.uk
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.