ING Intermediate Holdings Limited v HMRC  EWCA Civ 2111
The Court of Appeal’s decision in this case, handed down on 13 December 2017, deals with fundamental concepts of VAT, namely whether there was a supply of services, and if so, whether it was ‘for consideration’, and if so, whether the consideration could be expressed in monetary form. The case concerns deposit accounts provided by two members of the appellant’s VAT group referred to as “IDUK” and the ability of the group to recover input tax.
Peter Mantle acted for the Respondents, instructed by HMRC.
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