Target Group Ltd v Revenue and Customs Comrs

Subject Matter

REVENUE — Value added tax — Exemptions — Financial transactions —Taxpayer making supplies of loan administration services to bank — Revenue deciding supplies being composite supplies of management of loan accounts liable to tax — Whether supplies exempt as transactions concerning deposit and current accounts, payments, transfers etc — Whether supplies exempt as transactions concerning debts — Whether loan accounts current accounts — Value Added Tax Act 1994, Sch 9, Group 5, items 1, 8 — Council Directive 2006/112/EC, art 135(1)(d)

[2019] UKUT 340 (TCC); [2020] STC 1, UT

[2021] EWCA Civ 1043; [2021] STC 1662, CA

REVENUE — Value added tax — Exemptions — Transactions concerning “payments, transfers, debts” — Taxpayer company administering loans issued by bank to customers — Taxpayer inputting information automatically resulting in payment from customer’s account to bank’s account via BACS system — Whether transactions concerning “payments” or “transfers” — Taxpayer inputting debit/credit entries into customers’ loan accounts with bank — Whether transactions concerning “debts” — Council Directive 2006/112/EC, art 135(1)(d)

[2023] UKSC 35; [2023] 1 WLR 3621; [2024] 1 All ER 367; [2023] STC 1770; [2023] WLR(D) 421, SC(E)

Appellate History