The Barclays VAT case has been running through the tax tribunal since 2024, and the dispute relates to a refusal by HMRC in 2017 to allow the banking giant to bring a US member into the UK VAT group, and considered territorial considerations, fixed establishment rules and protection of the revenue rules.

The dispute arose with HMRC nearly a decade ago over a VAT group application. The First Tier Tribunal (FTT) ruled in favour of HMRC in respect of the fixed establishment decision, but the Upper Tribunal has now heard the appeal.

The lead appellant, Barclays Execution Services Ltd (BESL) is the representative member of a VAT group within the Barclays corporate group.