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Tax and the City review for November 2023

Speed read
The Supreme Court in Target Group decides that the financial services exemption should be construed narrowly and does not apply to the loan administration services supplied in this case. Draft legislation is published for inclusion in the next Finance Bill to ensure that supremacy of EU law will continue to apply for the purposes of interpreting VAT and excise law (so the principle of consistent interpretation remains applicable), but VAT and excise law can no longer be quashed or disapplied for being incompatible with EU law. The Supreme Court in Vermilion decides that the relevant option is an employment-related securities option pursuant to the deeming provision in ITEPA 2003 s 471(3). HMRC updates its guidance on the double tax treaty passport scheme with some timing changes worth noting.
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