The gold trader has lost an appeal at the High Court over whether supplies of gold bullion should be treated as exempt, rather than zero-rated, from VAT
Glint Pay Services offered retail customers the opportunity to purchase, save and spend gold through a bespoke mobile application that operated under the Mastercard system allocating e-money accounts and a separate gold account to customers.
The gold was held in Switzerland by a member of the London Bullion Market Association (LBMA), based in Zurich, in the custody of StoneX, who was the sole liquidity provider to Glint.
In the course of Glint’s application for approval of a partial exemption, HMRC submitted that its sales to clients were exempt supplies of investment gold under Group 15 of Schedule 9 to the Value Added Tax Act 1994 (VATA).
Note 4 of Group 15 states that ‘this group does not include a supply (a) between members of the LBMA, or (b) by a member of that association to a taxable person who is not a member or by such a person to a member.’
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