BlackRock Investment Management (UK) Ltd v The Commissioners for HM Revenue and Customs: [2018] UKUT 0415 (TCC)

Upper Tribunal Tax and Chancery decision of Mrs Justice Falk and Judge Berner on 20 December 2018.

Read the full decision in BlackRock Investment Management (UK) Ltd v The Commissioners for HM Revenue and Customs: [2018] UKUT 0415 (TCC).

VAT – exemption for management of special investment funds (SIFs) – Article 135.1(g), Principal VAT Directive (2006/112/EC) – single supply of an integrated trading, portfolio management and risk reporting software application – whether “management” of SIFs – whether the consideration for the supply could be apportioned so as to be exempt in so far as used to manage SIFs and taxable in so far as used to manage non-SIFs – reference of apportionment issue to the CJEU.

Published 20 December 2018