UK’s Top Court Upholds Value-Added Tax on Intragroup Fees (1)

The UK’s tax authority correctly charged taxes on intragroup performance fees between companies that were previously part of the same value-added tax group, the country’s top court said Thursday.

The UK Supreme Court dismissed an appeal by Prudential Assurance Company Ltd., which argued performance fees charged by Silverfleet Capital Ltd., a fund management company, shouldn’t be subject to VAT because their services had been provided while both companies were still members of the same VAT group.

The court agreed with the Court of Appeal’s ruling that, under VAT law, a supply of services is considered to take place at ...