JPMorgan Chase Bank, NA v The Commissioners for HMRC

Burden of proof lies on the appellant.

Grunwick Processing Laboratories Ltd v Commissioner of Customs and Excise [1987] STC 357

Each supply is normally distinct and independent, unless elements are so closely linked they form a single indivisible economic supply (Levob) or one is principal and others ancillary (CPP).

Honourable Society of Middle Temple v HMRC [2013] STC 1998; Spectrum Community Health CIC v HMRC [2022] UKFTT 237 (TC); Frenetikexito – Unipessoal Lda v Autoridade Tributária e Aduaneira (Case C-581/19)

When determining the nature of a transaction for VAT purposes, the court must look at the economic purpose of the transaction, starting with the parties' agreement. The court only goes behind the contract if it doesn't reflect the true agreement.

ING Intermediate Holdings Ltd v HMRC [2018] STC 339; HMRC v Airtours Holidays Transport Ltd [2016] STC 1509

Financial services exemptions are to be interpreted strictly and determined by the nature of services, not the supplier or receiver. Actual execution of a financial transaction is necessary for exemption, not merely giving instructions.

Target Group Limited v HMRC [2021] STC 1662; Sparekassernes Datacenter v Skatteministeriet [1997] STC 932

Classification of a supply cannot depend on the use of goods or services supplied.

BlackRock Investment Management (UK) Ltd v HMRC [2020] STC 1445

Sections 43(1)(a), 43(2A), and 43(2B) VATA govern the treatment of intra-group supplies.

Value Added Tax Act 1994

Article 135 of the Principal VAT Directive details exemptions for financial transactions.

Council Directive 2006/112/EC

Schedule 9, Group 5 of VATA specifies exempt financial supplies.

Value Added Tax Act 1994