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09 June 2008
Categories: Tax cases
CRC v AXA UK plc, Chancery Division, 22 May 2008

D Ltd a subsidiary of AXA PPP Healthcare Group plc provided various administrative and support services to dentists. These included payment handling in respect of payment plans under which a patient agreed to pay his dentist a fixed monthly sum in return for a specified amount of dental care. The company charged the dentist a small fee for each monthly payment.

D Ltd was a member of a VAT group of which AXA UK plc was representative member.

The company claimed repayment of overpaid VAT for the quarterly periods from March 2002 to December 2004. HMRC refused the claim.

The issues were whether:

  • the monthly fees charged by the company were exempt as a financial service as provided in VATA 1994 Sch 9 group 5 or item 5;
  • the services provided by the company in return for the composite supply was taxable or...

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