Exemption – Outsourcing by an exempt trader – Whether supplies made by the outsourcing company to the exempt trader were themselves exempt – Whether the outsourcing company made supplies which were a specific and essential part of the main exempt supply – Directive 77/388, sixth VAT directive, art. 13(B)(d).
The issue was whether supplies made by Sun Alliance Life Ltd in connection with the Daisy personal equity plan (PEP), which were effectively all dealings with the public preparatory to the issue and disposal of units held in the PEP, were exempt supplies.
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