- Management of Special Investment Funds (SIFs) is VAT exempt under the EU Principal VAT Directive (PVD)
- CCLA Investment Management Ltd provided fund management services to charitable, Church of England, and local authority investment funds
- Funds that are constituted as Undertakings for Collective Investment in Transferable Securities (UCITS) qualify as SIFs
- Funds that are not UCITS may benefit from the SIF exemption if they are equivalent or sufficiently comparable to a UCITS
- State supervision could be indirect, but must be financial in nature and regulated by the Financial Conduct Authority in the UK
- The First-tier Tribunal held that some funds met the criteria for VAT exemption on management services
- The decision did not cover the input tax position, so the refund amount for CCLA remains to be determined.
Source: taxscape.deloitte.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.
