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Exemption for management of special investment funds

14 January 2019
Issue: 4679 / Categories: Tax cases , VAT
BlackRock Investment Management (UK) Ltd v CRC, Upper Tribunal (Tax and Chancery Chamber), 20 December 2018
BlackRock UK received services through a platform Aladdin supplied by its fellow group company in the US BlackRock Financial Management Inc. The platform managed the business’s assets including special investment funds (SIFs). The management of SIFs is exempt from VAT under the Principal VAT Directive Art 135.1(g).
 
The issue was whether BlackRock was required to account for VAT under the reverse charge mechanism on the supply of Aladdin services to it by BlackRock US. BlackRock contended that they were exempt under Art 135.1(g) because they were used in the management of SIFs. HMRC considered the whole service should be standard rated.
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