In Zipvit, the UT held that HMRC was entitled to deny input VAT recovery where the taxpayer did not hold a valid VAT invoice and had not borne the economic burden of the VAT. In Taylor Clark, the Court of Session held that a VAT refund claim made by a member of a VAT group should be treated as being made on behalf of the group’s representative member. In Revenue & Customs Brief 11/2016, HMRC has changed its guidance on TOGC transactions involving VAT groups in light of the UT decision in Intelligent Management Services. In ING Intermediate Holdings Ltd, the UT held that the provision of bank accounts to customers (for which no fees were charged) involved a supply of services for consideration for VAT purposes.
