JPMORGAN CHASE BANK N.A. v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2025] UKUT 00188 (TCC)

Upper Tribunal Tax and Chancery decision of JUDGE SWAMI RAGHAVAN and JUDGE PHYLLIS RAMSHAW

• From: HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
• Published: 20 June 2025

• Category: Tax
• Release date: 17 June 2025

Read full decision JP Morgan Chase Bank NA v The Commissioners of His Majesty’s Revenue and Customs

VAT – Intra-group provision of services by infrastructure providing entity within group – issue arising over whether supply or supplies taxable under s43(2A) and (2B) VATA – whether single supply of support functions or multiple supplies of trading infrastructure services specific to particular business areas – whether if more than one supply whether any exempt under Payment or Securities exemption (Schedule 9, Group 5 VATA Article 135(1)(d) and/or (f) Principal VAT Directive) – appeal dismissed

Published 20 June 2025