RCB/22/14 VAT—CJEU judgment regarding deduction of VAT on pension fund management costs (PPG Holdings BV)

RCB/22/14 VAT—CJEU judgment regarding deduction of VAT on pension fund management costs (PPG Holdings BV)

Revenue & Customs Brief, Issue 22. 27 May 2014

Purpose of this Brief

HM Revenue & Customs (HMRC) issued Revenue and Customs Brief 6/14 (RCB/6/14, Division V16.3) to set out its position following the decision of the Court of Justice of the European Union (CJEU) in PPG Holdings BV (C-26/12) (PPG). This Revenue and Customs Brief is being issued to provide an update on HMRC's position following the CJEU's decision in ATP Pension Services (C-464/12) (ATP) and to extend the transitional period announced in RCB/6/14.

1.1 Readership

This Revenue and Customs Brief is primarily aimed at—

1.  

   —     businesses and other taxable entities that provide pension schemes for their employees

2.  

   —     pension fund management providers

3.  

   —     pension scheme trustees

4.  

   —     tax advisers

1.2 Background

PPG concerned an employer's entitlement to deduct VAT paid on services