RCB/43/14 VAT on pension fund management costs

Part V16 Forms and other HMRC material

RCB/43/14 VAT on pension fund management costs

RCB/43/14 VAT on pension fund management costs

Revenue & Customs Brief, Issue 43 25 November 2014

Purpose of this brief

This brief sets out the position of HM Revenue and Customs (HMRC) 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). The 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.

RCB/6/14 set out HMRC's initial reaction to the judgment. However, following the subsequent decision in the case of ATP Pension Services (C-464/12) (ATP) and discussions with industry representatives HMRC issued RCB/22/14 announcing that businesses could continue to use the transitional arrangements outlined in RCB/6/14 whilst the VAT treatment of pensions was reconsidered.

This brief outlines the position of HMRC following that process and deals with the circumstances when an employer may deduct VAT that is charged on services provided in relation to pension schemes. A separate brief has been issued to explain the circumstances where VAT is not chargeable on such services following the ATP decision.

You can read the full text of the PPG and ATP decisions on the CURIA website (

1.1 Readership

This brief is aimed at—


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


    —     pension fund management providers


    —     pension scheme trustees and pension providers


    —     tax advisers

1.2 Background

PPG, a Dutch company, established

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