In Target Group v HMRC [2018] UKFTT 226 (20 April 2018) the FTT found that the loan administration services supplied by Target fell within the debt collection carve out and were therefore not exempt (VATA 1994 Sch 9 Group 5).
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.
The FTT observed that whether a composite supply is exempt is generally determined by its predominant element viewed objectively from the perspective of the consumer. It found that...
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