(1) BARCLAYS SERVICES CORPORATION (2) BARCLAYS EXECUTION SERVICES LIMITED v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2026] UKUT 00211 (TCC)
Upper Tribunal Tax and Chancery Decision of MR JUSTICE RAJAH and JUDGE THOMAS SCOTT on 08 June 2026
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VALUE ADDED TAX – VAT grouping – HMRC decision to refuse admission of First Appellant to VAT group – whether First Appellant had a fixed establishment in the UK at date of application for grouping – whether decision to refuse grouping on alternative ground of being necessary for the protection of the revenue was reasonable – whether a conforming construction of the UK VAT grouping rules to restrict their territorial ambit is possible
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Published 8 June 2026