Commentary

RCB/65/07 VAT—JP Morgan Fleming Claverhouse Trust plc—fund management services

Part V16 Forms and other HMRC material

RCB/65/07 VAT—JP Morgan Fleming Claverhouse Trust plc—fund management services

RCB/65/07 VAT—JP Morgan Fleming Claverhouse Trust plc—fund management services

Revenue & Customs Brief, Issue 65. 5 November 2007

This Revenue & Customs Brief announces that HMRC have withdrawn from the appeal in JP Morgan Fleming Claverhouse Trust plc.

On 28 June 2007, the European Court of Justice (ECJ) delivered its judgment in this case which gave guidance for the VAT Tribunal to decide, on the facts, whether fund management services provided to investment trust companies (ITCs) should be exempt from VAT.

After careful consideration of the ECJ judgment, we now accept that fund management services supplied to ITCs are exempt and have withdrawn from the appeal. We remain of the view, published in Revenue & Customs Brief 58/07 (RCB/58/07, Division V16.3) that the judgment does not apply to

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