GE Aircraft Engine Services Ltd v HMRC

In GE Aircraft Engine Services Ltd v HMRC (Case C‑607/20) (17 November 2022) the CJEU held that no deemed supply of services arose for VAT purposes on vouchers given away free of charge by a company as part of its employee recognition scheme.

The taxpayer was a UK business operating in the UK in the aircraft manufacturing sector and was part of the international General Electric group. The group set up a programme called ‘Above and beyond’ under which employees could nominate colleagues they deemed deserving of a reward for performance. One category of reward offered was retail vouchers.

During the period in question transfers of retail vouchers subsequent to their issue were typically treated as supplies of services subject to VAT (the voucher rules were subsequently amended on an EU-wide basis from 1 January 2019). In addition the legislation required (in simple terms) a deemed supply to be...

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