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