BB/26B/04 VAT—treatment of services supplied by Independent Financial Advisor (IFA) networks
Business Brief, Issue 26. 17 September 2004
This Business Brief article clarifies the VAT treatment of services supplied by Independent Financial Advisor (IFA) networks and their appointed representatives (ARs).
Background
Customs are aware there has recently been some concern over the VAT treatment of services supplied under arrangements that allow IFA firms, authorised to carry out regulated activities under the Financial Services and Markets Act 2000 (FSMA), to operate as networks for non-authorised financial advisers. Under these arrangements, the authorised IFA firm takes regulatory responsibility for non-regulated advisers, known as appointed representatives, enabling the ARs to carry out regulated activities without the need to be authorised directly by the Financial Services Authority (FSA).
Currently, “regulated activities” means the selling of investment products. This will extend to the selling of mortgages from 31 October 2004 and to general insurance sales in January 2005. This Business Brief only applies to regulated activities provided under IFA network arrangements.
These network arrangements are permitted under s 39 of the FSMA and are subject to strict regulatory rules.