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BlackRock: single supply, dual use – apportionment?

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BlackRock (Case C-231/19) concerns VAT on a single supply of investment management services used to manage both special investment funds (SIFs) and non-SIFs. In that case, the CJEU ruled that the potential for dual use meant the exemption for the management of SIFs cannot apply, so the supply was standard rated in its entirety. The decision in Luxembourg to the effect that a supply could in principle be exempt only in part was dismissed as irrelevant. The suggestion from BlackRock is that all dual or multi-capable services that may be ‘used in the same way for the management of special investment funds as for the management of other funds’ are by definition excluded from the SIF exemption; however, this seems unduly restrictive, and no doubt the exemption will continue to develop.

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