Summary
This was an appeal against a decision by HMRC to reject a voluntary disclosure by the appellant for nearly £19 million on what they considered to be overpaid VAT on payment handling services which the appellant considered to be exempt from VAT.
Background
The First Tier Tribunal (FTT) considered a number of issues:
- whether payment handling charges were exempt (under VATA 1994, Gp 5, Sch 9, items (1) and (5);
- whether the supply was separate from other media services;
- which VAT group member made the supply;
- whether there was an intra-group supply; and
- whether there was an abuse of