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CGI Group (Europe) Ltd v HMRC (No 2)

In CGI Group (Europe) Ltd v HMRC (No 2) (TC00678 – 27 September) an insurance company (CS) outsourced its IT department to another company (CG). It was agreed that the relevant employees would be joint employees of CS and CG. HMRC issued an assessment to CG charging output tax on the amounts which it received from CS under the relevant agreement. CG appealed contending firstly that the payment was outside the scope of VAT and alternatively that it had a legitimate expectation that the effect of Notice 700/34 was that there was ‘no supply of staff for VAT purposes’.

The Tribunal reviewed the evidence in detail rejected these contentions and dismissed the appeal holding that ‘VAT is chargeable on the whole of the consideration’. The Tribunal held that Notice 700/34 should be understood as making a distinction ‘between a supply of staff of which “the...

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