Commentary

RCB/58/07 VAT—claims in respect of fund management services

Part V16 Forms and other HMRC material

RCB/58/07 VAT—claims in respect of fund management services

RCB/58/07 VAT—claims in respect of fund management services

Revenue & Customs Brief, Issue 58. 22 August 2007

Background

The EC VAT Directive (formerly the Sixth Directive) exempts “management of special investment funds as defined by member states”. The UK applies this exemption to the management of authorised unit trusts (AUTs), open-ended investment companies (OEICs) and trust-based schemes. The UK has not applied this exemption to the management of other funds, including investment trust companies (ITCs).

In 2004, JP Morgan Fleming Claverhouse Trust plc, an ITC, appealed to the VAT Tribunal against the VAT charged to it on investment management services. This appeal was

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