Jupiter Asset Management Group Ltd v HMRC

In Jupiter Asset Management Group Ltd v HMRC [2021] UKFTT 96 (TC) (9 April 2021) the First-tier Tribunal (FTT) ruled in favour of HMRC over the methodology used to calculate output tax assessments.

The taxpayer Jupiter Asset Management Group Ltd (JAMG) is the representative member of a VAT group. JAMG was also a member of a corporate group (Jupiter Group). There is also another VAT group in the Jupiter Group and the representative member of that group was Jupiter Investment Management Group Ltd (JIMG).

The nature of the relationship between the members of the corporate group and the inter-group supplies made were complex.

The appeal concerns input tax and output tax consequences for JAMG in respect of certain strategic and operational management service charges provided by members of the JAMG group to members of the JIMG group. When the first management services agreement (MSA) was agreed a cost...