Exempt payment services supplied to non-EU corporate group member: American Express Services Europe Limited v HMRC [2019] UKFTT 548 (TC)

The First Tier Tribunal (FTT) has found, both on contractual analysis and in commercial reality, that the Taxpayer, a member of the American Express corporate group, made exempt supplies of payment services to a non-EU member of the same group. The Taxpayer was therefore entitled to claim some £57m of input VAT in relation to these services.