The summary of responses to the consultation on VAT treatment of fund management services indicates that very little will change. In Euromoney, the Court of Appeal concludes that, when applying the purpose test in TCGA 1992 s 137, the whole of the taxpayer’s scheme or arrangements must be considered, and not just a select part of them. Recent developments on Pillar Two include revised draft guidance from HMRC and a further tranche of agreed administrative guidance from the Inclusive Framework. The latest report on the tax contribution of the banking sector estimates the total tax contribution for 2022/23 to be £41bn but shows that London is looking less attractive from a tax perspective than some other major finance centres.
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The summary of responses to the consultation on VAT treatment of fund management services indicates that very little will change. In Euromoney, the Court of Appeal concludes that, when applying the purpose test in TCGA 1992 s 137, the whole of the taxpayer’s scheme or arrangements must be considered, and not just a select part of them. Recent developments on Pillar Two include revised draft guidance from HMRC and a further tranche of agreed administrative guidance from the Inclusive Framework. The latest report on the tax contribution of the banking sector estimates the total tax contribution for 2022/23 to be £41bn but shows that London is looking less attractive from a tax perspective than some other major finance centres.
If you are not a subscriber, subscribe now to read this content.
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