Tax

Ing Intermediate Holdings Ltd v Revenue & Customs

[2014] UKFTT TC TC04051First-tier Tribunal (Tax)2014

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VAT - claim to recover input tax incurred by bank in providing deposit accounts - deposit accounts provided �free of charge� to bank�s customers - whether supply for consideration � yes � whether consideration capable of valuation � yes - appeal dismissed

K Prosser QC and Mr J Rivett, Counsel, instructed by PricewaterhouseCoopers LLP� for the Appellant

K Beal QC and Mr P Mantel, Counsel, instructed by the General Counsel and Solicitor to HM Revenue and Customs, for the Respondents

The appellant (�ING�) is a UK registered company and the representative member of a VAT group which included the two companies which made the supplies at issue in this appeal, ING Direct (UK) NV and ING Direct NV, both Dutch companies.

It made various voluntary disclosures (the first in 2006 and the last in 2011) that it had failed to deduct input tax amounting to �6,032,280 in the periods 10/02 to 03/11.� The claims were rejected by HMRC in decision letters issued in 2010 and 2011.� The appellant lodged various appeals against these decisions which were consolidated into one.

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