Jupiter Asset Management Group Limited v Revenue and Customs: FTTTx 9 Apr 2021

Managment Services Made Between Two Vat Groups

VALUE ADDED TAX – supplies of management services made between two VAT groups within the same corporate group – whether supplies made at less than open market value – in the absence of comparable supplies, open market value was to be determined by reference to the full cost of making the supplies – that full cost included the costs incurred on goods and services used in making the supplies and also general overhead costs the input tax in respect of which had been recovered – it also included the remuneration paid to the executive directors to the extent that that remuneration related to activities performed by the executive directors in making the supplies of the management services – appeal against the output tax assessments dismissed – whether input tax on general overhead costs incurred by a holding company carrying on only the economic activity of making supplies of management services recoverable – yes

[2021] UKFTT 96 (TC)
England and Wales


Updated: 10 November 2021; Ref: scu.663706