Commentary

BB/21A/05 VAT—clarification of the treatment of foreign exchange transactions (forex)

Part V16 Forms and other HMRC material

BB/21A/05 VAT—clarification of the treatment of foreign exchange transactions (forex)

BB/21A/05 VAT—clarification of the treatment of foreign exchange transactions (forex)

Business Brief, Issue 21. 23 November 2005

This Business Brief clarifies HM Revenue and Customs' (HMRC) policy regarding forex transactions, following the Tribunal decision in Willis Pension Fund Trustees Limited (Willis) (2005) VAT Decision 19183. HMRC has decided not to appeal this decision.

Background

Willis was the Trustee of the Willis Pension Fund, which was a pension scheme for the employees of the Willis Group Holding Limited group of companies. The scheme held various investments, including a number of overseas investments and equities. As a result, the sterling value of these assets was subject to exchange rate fluctuations. Willis entered into forex deals with various UK banks,

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