Visit JCPCUKSC/2021/0189
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TAX
Target Group Ltd (Appellant) v Commissioners for His Majesty's Revenue and Customs (Respondent)
Case summary
Case ID
UKSC/2021/0189
Parties
Appellant(s)
Target Group Ltd
Respondent(s)
Commissioners for His Majesty's Revenue and Customs
Issue
Whether outsourced loan administration services supplied by Target are standard rated supplies for VAT purposes, or if they fall under the "financial services exemption" under article 135(1)(d) of the Principal VAT Directive, implemented in the Value Added Tax Act 1994 (VATA)?
Facts
Target provides outsourced loan administration services to customers. In May 2015, Target sought a Non-Statutory Clearance from HMRC concerning its VAT liability in respect of these services, contending that they are exempt from VAT. HMRC responded with a letter setting out its position that Target's services were vatable. Target requested a review of that decision, which HMRC upheld upon review. Target appealed to the First Tier Tribunal, which was unsuccessful. The Upper Tribunal also held that these services were vatable. Target appealed to the Court of Appeal, which confirmed the decision of the Upper Tribunal. Target now appeals to the Supreme Court.
Date of issue
14 September 2021
Judgment appealed
Judgment details
Judgment date
11 October 2023
Neutral citation
[2023] UKSC 35
Judgment links
Judgment summary
11 October 2023
Appeal
Justices
Hearing dates
Full hearing
Start date
12 July 2023
End date
13 July 2023
Watch hearings
12 July 2023 - Morning session
12 July 2023 - Afternoon session
13 July 2023 - Morning session
13 July 2023 - Afternoon session
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Change log
Last updated 16 April 2024