Single supply of investment management services

16 July 2020

Issue: 4753 / Categories: Tax cases

BlackRock Investment Management (UK) Ltd v CRC (Case C-231/19), Court of Justice of the EU, 2 July 2020

The taxpayer received investment management services through a software platform Aladdin supplied by its US parent. These services were used for the management of various investment funds including special investment funds (SIFs). The management of SIFs is exempt under Directive 2006/112/EC art 135(1)(g).

It was agreed that there was a single supply of investment management services but Blackrock argued that it should account for VAT under the reverse charge mechanism on the supply that related to the management of other funds only.

The Upper Tribunal referred the matter to the Court of Justice of the EU (CJEU).

The CJEU held that a single supply must be subject to a single tax treatment. To apply a single rate to the services provided by the Aladdin platform could lead to the benefit of the exemption for the management of special investment funds being accorded to other funds. That could lead to...

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