Fund Management
27/09/1996
Query
Treatment of services supplied by Commodity Trading Advisors (CTA's) based outside the State with delegated authority to manage a "qualifying" fund in the State. The CTA's are not part of the same corporate structure as either the Irish-based fund, the Irish-based statutory manager or the de-facto manager.
Decision
In the circumstances of the case Revenue accepted that services were supplied to the Investment Manager based outside the State for onward supply to the qualifying fund and as such was not regarded as relating to services received in the State. Therefore a Fourth Schedule liability to Irish VAT would not arise.
Value Added Tax
Schedule 1, Value Added Tax Act, 1972
Origin: Indirect Taxes Policy and Legislation
File ref:A/373