VAT representative meaning

The Prudential Assurance Company Ltd v HMRC [2024] EWCA Civ 300 The Prudential Assurance Company Ltd (Prudential) acted as the representative member of its VAT group. Another company in the group, Silverfleet Capital Ltd (SCL), executed an investment management services contract to provide services to Prudential. Under that contract, SCL was also eligible for a management fee and deferred performance fees once a specified hurdle rate was achieved. Under section 43 of the Value Added Tax Act 1994 (VATA 1994), no VAT was payable on the management fee because they were in the same VAT group. In 2007, SCL exited the VAT group. In 2014 and 2015, the triggers for paying the further deferred performance fee were satisfied and SCL invoiced Prudential for over £9m in total. The question before the Court of Appeal was whether those additional performance fees ultimately constituted consideration for a supply made while both companies were members of the same VAT group or, alternatively, whether the services amounted to a continuous supply of services...

Monmore Properties Ltd v HMRC [2024] UKFTT 127 (TC) The appellant acted as the representative member of a Value Added Tax (VAT) group. The tribunal’s determination arose from a preliminary hearing convened to resolve two threshold issues: whether the appellant’s appeal had been brought within time, and whether HMRC’s assessments covering a 27‑month span (five VAT return periods) were out of time. The broader controversy was not addressed at this stage, as it was a matter for the substantive appeal, and concerned the VAT treatment of services provided by VAT group members to persons outside the VAT group. At the preliminary hearing it was also established that HMRC had not issued a single global assessment. That clarification was relevant because the wider dispute referred to...

In this issue: Individuals and income tax Employment taxes Budgets and Finance Bills Companies and corporation tax International Tax compliance and administration Daily and weekly news alerts New and updated content Latest Q&A Dates for your diary Trackers Useful information Individuals and income tax High Court allows taxpayer to pursue judicial review regarding his historic domicile status (Aubrey Weis v HMRC). As noted in last week’s highlights, in Aubrey Weis v HMRC [2025] EWHC 2479 (Admin), the High Court accepted the claimant’s request to extend the deadline for issuing judicial review proceedings against HMRC and approved permission for the matter to go forward to a full hearing. The case turns on the taxpayer’s historic domicile and whether he held a legitimate expectation that HMRC would treat him as non-UK domiciled, so that his overseas income and gains would be assessed on the remittance basis. See News Analysis: High Court permits taxpayer to...

This Practice Note offers practical guidance on obtaining a duty deferment account in Great Britain and Northern Ireland to delay payment of import duties, excise duties and, where appropriate, import VAT. It explains who can apply, how to seek a guarantee waiver, and which supporting documents must be provided. Introduction Payment of customs duties, excise duties and import VAT on imported goods can be deferred. To achieve this, an importer (or a representative acting for the importer) must apply for a duty deferment account. Once approved, the importer makes a single monthly payment covering customs duties, excise duties and import VAT, removing the need to pay for each individual consignment. Payment is collected by direct debit. Set up the importer’s direct debit via the Customs Declaration Service (CDS). Importers registered for VAT may account for import VAT on their VAT return instead of paying it through the duty deferment account. Some traders can also defer import VAT. Such traders are either: not VAT-registered, or...

Private Client England & Wales glossary A Abatement When, after settling the deceased’s funeral costs, debts and liabilities, the remaining estate cannot satisfy all legacies in full, the gifts are reduced accordingly, unless the Will shows a different intention. In a solvent estate, the order for reduction appears in Part II of Schedule 1 to the Administration of Estates Act 1925. Refer to Practice Note: Payment of legacies. Accruals basis Where income is taxed on an accruals basis, it is attributed to a given tax year by reference to the number of days within that year during which the activity giving rise to the liability accrued. See Practice Note: What is the basis of income tax?. Accumulation and maintenance (A&M) trust A form of non‑interest in possession trust designed to benefit children and young people up to 25, which received favourable inheritance tax treatment between 1975 and 2006. See Practice Note: Accumulation and maintenance trusts—IHT [Archived]. Accredited Legal Representative (ALR) ...

Updated in January 2026 Introduction Despite its modest size, the Grand Duchy of Luxembourg (Luxembourg) ranks among the world’s powerhouses for commerce and stands as a leading European financial and industrial centre. It draws investment banks, asset managers, funds and holding vehicles, as well as firms in information and communication technology and the space sector, from across the globe, positioning it as a favoured gateway into the EU and a major business hub. Owing to political, social and legal stability, and to the determination of its political class to nurture a business-friendly setting, Luxembourg has earned a name for pro-business legislation and administration. This guide, for companies looking to establish in Luxembourg, sets out a comprehensive overview of the key features of Luxembourg law that should be considered before beginning operations in Luxembourg. That said, however complete it appears, it is not an all-inclusive account of Luxembourg law, and bespoke legal advice should always be obtained before creating a business in Luxembourg. The business environment Luxembourg...

3 Collaboration Objectives and Steering Group The parties agree to: Maximise the overall value of the Development Site, taking account of good planning practice. Settle the Master Plan as soon as reasonably practicable. Secure a Satisfactory Planning Permission for the Development (including Enabling Works and Shared Infrastructure), and thereafter: obtain any agreed Funding; deliver the Enabling Works and Shared Infrastructure promptly, efficiently and on time; and approve and implement the Sale Strategy. Apportion the Collaboration Expenses and any Development Profit or Development Loss in the stated Proportions, unless this Agreement provides otherwise. The Steering Group must: Provide strategic direction to achieve the Collaboration Objectives, including agreeing variations, monitoring progress and issuing instructions. Meet at least monthly (or more often if required); each party will use all reasonable endeavours to ensure its representative, or a suitably senior substitute, attends; minutes are to be taken on rotation and circulated within five Working Days. Invite appointed consultants and...