A UK tribunal rejected an appeal by Barclays entities seeking tax savings, including a one-off £21 million ($28 million) benefit, by adding a US subsidiary to their UK value-added tax group.
Barclays Services Corp., a Delaware subsidiary within the Barclays group, lacked actual or comparable control over any employees or technical resources as of Dec. 1, 2017, and therefore didn’t form a fixed establishment in the UK, the Upper Tribunal said Monday in its judgment.
In December 2017, Barclays Execution Services Ltd., a UK company, applied to add BSC to the group on the basis that both were part ...