RCB/17/15 Deduction of VAT on pension fund management costs
Revenue & Customs Brief, Issue 17. 14 September 2016
Purpose of this brief
This brief follows on from RCB/43/14 “VAT on pension fund management costs”, RCB/8/15 “Deduction of VAT on pension fund management costs”. You should also read RCB/14/16 “VAT—deduction of VAT on pension fund management costs following Court of Justice of the European Union decision in PPG”, which extends the transitional period to 31 December 2017 and updates HMRC's position.
These briefs set out our position following the decision of the Court of Justice of the European Union (CJEU) in Fiscale Eenheid PPG Holdings BV cs te Hoogezand (C-26/12) (PPG). This case concerned an employer's entitlement to deduct VAT paid on services relating to the administration of defined benefit pension schemes and the management of their assets.
When first published, this brief announced the extension of the transitional period until 31 December 2016. On 5 September 2016 the transitional period was further extended to 31 December 2017, as outlined above. This brief also provides an update on HMRC's position on possible arrangements for employers to achieve VAT deduction for the costs of administering occupational pension schemes and managing their assets going forward.
This brief is aimed at—