BlackRock Investment Management (UK) Ltd v HMRC

In BlackRock Investment Management (UK) Ltd v HMRC (Case C-231/19) (2 July) the CJEU ruled that a single supply of investment management services cannot be taxed at multiple rates.

The appellant received supplies of investment management services in the form of a software platform known as Aladdin from its US parent. These services were used for the management of various investment funds including special investment funds (SIFs). The management of SIFs is exempt under Directive 2006/112/EC article 135(1)(g); the management of other funds is taxable.

The parties agreed that there was a single supply of investment management services; however Blackrock argued that only the element of the supply which related to the management of other funds should be taxable (by means of the reverse charge). This element should be calculated according to the value of the other funds to the value of all funds.

The CJEU held...

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