Consideration & supply – a new case

Les Howard
VAT Consultant
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In the case of Lloyds Banking Group, HMRC sought to unpick a batch of contracts, such that payments relating to a TUPE constituted consideration for a supply, leading to a £5m assessment. I am pleased to report that the First Tier Tribunal rejected this argument.

But the case is a warning that HMRC may seek to ‘drill down’ into ordinary commercial arrangements in their quest for revenue.

The decision is here:


About Les Howard


Hi, I am a VAT Consultant, working mainly with charities. I am based in Cambridgeshire

I have over 20 years experience in VAT, and am currently also a part-time member of the Tax Tribunals.


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