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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
Gary Barnett
Jo Crookshank
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
The new Securities Transfer Tax: business as usual?
Georgina West
1 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
2 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
3 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
4 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
5 /7
Estoppel and abuse of process in VAT
Claire Logan
6 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
7 /7
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
NEWS
Read all
Tax Journal thanks its July 2026 authors
GAAR Advisory Panel issues Opinions on IHT planning arrangements
CIOT and ATT suggest priorities for new Financial Secretary
Pillar Two top-up taxes returns: deadline reminder
ATT cautions against ITSA ‘timely payment’ reforms
CASES
Read all
Ten cases shaping tax practice in 2026
New cases this week: 31 July 2026
M Elborne and others v HMRC
E Kwai v HMRC
P Reed v HMRC
IN BRIEF
Read all
Funding the business
HMRC’s annual report for 2025/26
The new duty to correct tax return errors
The VAT treatment of prize draws
Directors’ liability: tax schemes
MOST READ
Read all
The VAT treatment of prize draws
The new duty to correct tax return errors
Loan charge settlement scheme: regulations and guidance published
Requirements for forthcoming pensions IHT changes
One minute with... Tim Gummer