- VAT groups: services invoiced after departure from VAT group are subject to VAT
- Prudential and Silverfleet were part of the same VAT group, but Silverfleet left in 2007
- Silverfleet invoiced Prudential for performance fees in 2014 and 2015, including VAT
- Prudential challenged HMRC’s view on VAT liability, arguing services were provided while in VAT group
- First-tier Tribunal ruled in favor of Prudential, but HMRC appealed to Upper Tribunal
- Upper Tribunal applied time of supply rules over VAT grouping rules, finding supply was not intra-VAT group
- Prudential appealed to Court of Appeal, which upheld Upper Tribunal’s decision
- Case is important for clarifying VAT liability for services provided within VAT groups.
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.
