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Single supply
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Single supply
SINGLE-SUPPLY
Inter-company outsourcing under scrutiny: VAT perspective after JPMorgan
Philippe Gamito
Philippe Gamito (Baker McKenzie) reviews an Upper Tribunal decision
which is likely to shape the way international businesses design in-house
outsourcing strategies.
Queenscourt Ltd v HMRC
VAT: single or multiple supplies
The VAT review for February 2026
Jo Crookshank
Gary Barnett
This month’s update by Jo Crookshank and Gary Barnett (Simmons & Simmons) covers share sales, substance over form and single supplies.
The VAT review for July 2024
Gary Barnett
Joao Martinho
Recent VAT decisions on card handling fees, single supply determinations and fixed establishments are reviewed by Joao Martinho and Gary Barnett (Simmons & Simmons).
Spectrum Community Health CIC v HMRC
Healthcare service provided in prisons was a single supply for VAT.
Other cases that caught our eye: 14 June 2024
VAT on KFC sauce pots: Queenscourt Ltd v HMRC [2024] UKFTT 460 (TC) (3 June 2024) concerned whether a supply of a sauce pot with a takeaway meal in a Kentucky Fried Chicken franchise was part of a standard rated supply of hot food or a separate...
Characterising a single supply following the Court of Appeal’s decision in Gray & Farrar
Sarabjit Singh
The Court of Appeal’s decision is likely to remain authoritative guidance
for some time on the question of how a single complex supply ought to be
characterised, writes Sarabjit Singh KC (1 Crown Office Row).
Single supply and VAT exemption for financial services: insights from JPMorgan
Anastasia Nourescu
Naima Khalid
Naima Khalid (EY) and Anastasia Nourescu (Stewarts) consider the impact
of the recent decision in JPMorgan.
Characterising supplies for VAT following Mesto Zamberk
Michael Thomas KC
The characterisation test for VAT has received important clarification from the Court of Appeal, writes Michael Thomas KC (Pump Court Tax Chambers).
BlackRock: single supply, dual use – apportionment?
Etienne Wong
Etienne Wong (Old Square Chambers) examines the CJEU’s decision concerning VAT on a single supply of investment management services used to manage both special investment funds and non-SIFs.
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EDITOR'S PICK
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
1 /7
The Orsted ‘tax nothing’
Andrew Page
2 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
3 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
4 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
5 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
6 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
7 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
NEWS
Read all
Tax Journal authors for October
Budget capital allowances changes: mixed picture for business investment decisions
Government declines to expand land remediation relief
HMRC publish new RTI guidance for employers
ERS: annual returns after scheme closure
CASES
Read all
Abbey Group Ltd v HMRC
Strauss Phillips & Co Ltd v HMRC
Education Training Collective v HMRC
Other cases that caught our eye: 30 October 2026
ScottishPower (SCPL) Ltd and others v HMRC
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
The Nigel Blackwell Family Trust and others v HMRC
One minute with... Helen Miller
Chancellor reportedly rejects alignment of CGT and income tax rates
ScottishPower (SCPL) Ltd and others v HMRC
Side-by-Side: four scenarios for 2030