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Tax and the City review for March 2019

Speed read
The Court of Appeal in Farnborough Airport confirms the appointment of a receiver triggers degrouping but does not have to consider whether the narrow interpretation of ‘control’ taken by the Upper Tribunal is correct. In Morrison Trustees, the Court of Appeal dismisses the taxpayers’ appeal concluding that there cannot be a strict requirement for ‘arrangements’ for the final sale to have been made by the time of the first transaction for Ramsay to apply. The Court of Appeal in Jimenez decides that HMRC has the power to serve information notices to a taxpayer resident abroad. In Blackrock the Upper Tribunal concludes that the provision of a technology platform can qualify as a substantive VAT exempt financial service (rather than as a standard rated supply of IT services) although a reference is being made to the CJEU on apportionment of the consideration.

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