Revenue Precedents

The group is regarded as a single taxable entity and accordingly a waiver of entitlement to exemption by a member of a group extends to all members of the group. A/311

VAT grouping of fund management company with all the funds and unit trusts under its management. In the circumstances of this case and in consideration of previous decisions made concerning the criteria established in relation to group registration it was agreed to allow group registration in this case on the understanding that the managed funds have no independent management capabilities and that the fund management company accepts joint and several liability for all the funds under its control. 941

VAT grouping of companies linked either financially or organisationally where their business is not economically linked. In the circumstances of a particular case a group arrangement was allowed for VAT purposes where all the criteria as provided in Section 8 (8) of the VAT Act did not apply i.e. the economic links were questionable. A/337