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Case details

Target Group Ltd (Appellant) v Commissioners for His Majesty's Revenue and Customs (Respondent)

Case ID: 2021/0189

Case summary


Whether outsourced loan administration services supplied by Target are standard rated supplies for VAT purposes, or if they fall under the "financial services exemption" under article 135(1)(d) of the Principal VAT Directive, implemented in the Value Added Tax Act 1994 (VATA)?


Target provides outsourced loan administration services to customers. In May 2015, Target sought a Non-Statutory Clearance from HMRC concerning its VAT liability in respect of these services, contending that they are exempt from VAT. HMRC responded with a letter setting out its position that Target's services were vatable. Target requested a review of that decision, which HMRC upheld upon review. Target appealed to the First Tier Tribunal, which was unsuccessful. The Upper Tribunal also held that these services were vatable. Target appealed to the Court of Appeal, which confirmed the decision of the Upper Tribunal. Target now appeals to the Supreme Court.

Judgment appealed

[2021] EWCA Civ 1043



Target Group Ltd


Commissioners for His Majesty's Revenue and Customs



Lord Reed, Lord Lloyd-Jones, Lord Sales, Lord Hamblen, Lady Rose

Hearing start date

12 July 2023

Hearing finish date

13 July 2023

Watch hearing
12 July 2023 Morning session Afternoon session
13 July 2023 Morning session Afternoon session

Judgment details

Judgment date

11 October 2023

Neutral citation

[2023] UKSC 35

This judgment was reuploaded on 20 October 2023 to correct a misnumbered heading.

Watch Judgment summary
11 October 2023 Judgment summary