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Intelligent Managed Services Ltd v CRC, Upper Tribunal (Tax and Chancery Chamber), 7 July 2015
The taxpayer I Ltd transferred its banking support services to VMMSL a member of the VM group. HMRC said this was not a transfer of a going concern because VMMSL was making supplies only to other group members.
The First-tier Tribunal dismissed the taxpayer’s appeal. It appealed to the Upper Tribunal.
The Upper Tribunal said nothing in the group rules prevented the transfer of the taxpayer’s business to VMMSL being a transfer of a going concern. The taxpayer transferred the whole of its business and the transferee intended to carry out that business. The effect of VMMSL being a member of the VM group was that the group was treated as the transferee and as carrying on the business. This did not change the nature of the businesses in the group in that they remained...
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