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VAT Grouping Revisited: Fixed Establishment and Revenue Protection in Barclays – Tax Litigation 2025

  • Article discusses appeal by two Barclays entities against HMRC’s refusal to allow US company to join UK VAT group
  • HMRC testing boundaries of fixed establishment for VAT grouping
  • Latest case is Barclays Service Corporation & Barclays Execution Services Ltd v HMRC [2024] UKFTT 00785 (TC)
  • Eligibility for VAT group under Article 11 of Council Directive 2006/112/EEC
  • HMRC can refuse application for revenue protection
  • Taxpayers can appeal to First-tier Tribunal against refusal
  • Background of case involving Barclays Service Corporation and Barclays Execution Services Limited
  • UK branch of US company involved in providing services to Barclays group members

Source: stewartslaw.com

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.

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