23 March 2021 
Andrea Marshall, Tax Specialist
Members will recall that this case considered whether Wellcome Trust was receiving the fund manager services of managing its investments as a taxable person - if it was, the result being that the place of supply of the services would be the UK and therefore subject to the reverse charge; if it was not, the place of supply would be where the fund manager was established and if there was no VAT system (or a lower rate of VAT than the UK applied) savings would arise.
Wellcome Trust has lost the case. It has been ruled that the fund managers were supplying their services to a taxable person and, therefore, that the place of supply of the fund managers services was the UK, thus subject to the Reverse Charge adjustment.
This now brings to a conclusion any cases or claims that members have, which have stood behind Wellcome Trust.
Grant Thornton's summary of this judgement can be found here.
KPMG's commentary on the case can be found here.
