The Value Added Tax (Finance) Order (SI 2020/209) has expanded the scope of the UK’s VAT exemption for fund management, mandating, rather than permitting, exemption for relevant defined contribution pension funds and listed real estate funds. However, whilst adopted in response to CJEU case law, the 2020 Order is unlikely to be the final chapter in the evolution of the UK’s implementation of the VAT Directive’s exemption for the management of ‘special investment funds’. Uncertainties remain, which it is to be hoped will be resolved following the forthcoming HMRC consultation in this area.
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The Value Added Tax (Finance) Order (SI 2020/209) has expanded the scope of the UK’s VAT exemption for fund management, mandating, rather than permitting, exemption for relevant defined contribution pension funds and listed real estate funds. However, whilst adopted in response to CJEU case law, the 2020 Order is unlikely to be the final chapter in the evolution of the UK’s implementation of the VAT Directive’s exemption for the management of ‘special investment funds’. Uncertainties remain, which it is to be hoped will be resolved following the forthcoming HMRC consultation in this area.
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