Target Group Ltd (Appellant) v Commissioners for His Majesty's Revenue and Customs (Respondent)
Case ID: 2021/0189
Case summary
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.
Judgment appealed
Parties
Appellant(s)
Target Group Ltd
Respondent(s)
Commissioners for His Majesty's Revenue and Customs
Appeal
Justices
Lord Reed, Lord Lloyd-Jones, Lord Sales, Lord Hamblen, Lady Rose
Hearing start date
12 July 2023
Hearing finish date
13 July 2023
| Watch hearing | ||
|---|---|---|
| 12 July 2023 | Morning session | Afternoon session |
| 13 July 2023 | Morning session | Afternoon session |
Judgment details
Judgment date
11 October 2023
Neutral citation
[2023] UKSC 35
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This judgment was reuploaded on 20 October 2023 to correct a misnumbered heading.
| Watch Judgment summary | |
|---|---|
| 11 October 2023 | Judgment summary |