In Target Group v HMRC [2019] UKUT 340 (15 November 2019) the UT found that loan administration services did not fall within the exemption for financial services.
The appeal concerned Target’s contractual arrangements with a bank Shawbrook which related to loans provided by Shawbrook to customers in the course of its lending business. Target provided ‘loan account administration services’. As an undisclosed agent of Shawbrook it established loan accounts liaised with borrowers dealt with their payments etc.
It was accepted that Target made a single composite supply to Shawbrook. The issue was whether the supply qualified for the exemption for financial services.
Agreeing with the FTT the UT found that the essential characteristic of both deposit and current accounts is that the customer is able to deposit and withdraw funds in varying amounts. In the case of the loan accounts with Shawbrook the customer...
