This month’s review by Jo Crookshank and Gary Barnett (Simmons & Simmons) covers recent decisions on the single/multiple supply rule and the VAT finance intermediation exemption, as well as HMRC’s change of policy on pension scheme costs.
Single supply of global support services
In JPMorgan Chase Bank NA v HMRC [2025] UKUT 188 (TCC) the Upper Tribunal upheld the 2023 First-tier Tribunal (FTT) decision that supplies of intra-group support services made between two group companies under a global master services agreement within the worldwide JPMorgan group amounted to a single taxable supply of services. The Upper Tribunal (UT) rejected the taxpayer’s criticisms of the FTT’s conclusion that it was not possible to separate supplies between those which were general taxable support services (general corporate functions including legal tax HR and IT) and supplies which might fall within the scope of the exemption for transactions...
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This month’s review by Jo Crookshank and Gary Barnett (Simmons & Simmons) covers recent decisions on the single/multiple supply rule and the VAT finance intermediation exemption, as well as HMRC’s change of policy on pension scheme costs.
Single supply of global support services
In JPMorgan Chase Bank NA v HMRC [2025] UKUT 188 (TCC) the Upper Tribunal upheld the 2023 First-tier Tribunal (FTT) decision that supplies of intra-group support services made between two group companies under a global master services agreement within the worldwide JPMorgan group amounted to a single taxable supply of services. The Upper Tribunal (UT) rejected the taxpayer’s criticisms of the FTT’s conclusion that it was not possible to separate supplies between those which were general taxable support services (general corporate functions including legal tax HR and IT) and supplies which might fall within the scope of the exemption for transactions...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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