Baillie Gifford & Co v HMRC

In Baillie Gifford & Co v HMRC [2019] UKFTT 410 (25 June 2019) the FTT applied a conforming interpretation to the VAT grouping provisions as they existed prior to FA 2019 to allow a Scottish partnership to be part of a group.

Baillie was a Scottish Partnership created under the Partnership Act 1890. It was not a body corporate. It was the sole shareholder of three companies.

Baillie provided investment management services to third parties such as large pension schemes and to its three subsidiaries. It was accepted that due to regulatory requirements governing financial services and investments providers the group’s business could not be provided solely through the structure of a partnership.

Baillie had applied to HMRC to form a VAT group with Baillie as its representative member and its three subsidiaries as its members. Group registration would mean that VAT would not be...

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