HMRC publishes GfC20 guidance on the VAT fund management exemption for outsourced services (10 September 2026)

What changed in detail

HMRC published Guidelines for Compliance GfC20, “Help with VAT on fund management services”, on 10 September 2026.

It sets out HMRC’s recommended approach to deciding whether outsourced fund management services are single or multiple supplies for the fund management exemption (Items 9 and 10 of Group 5, Schedule 9 VATA 1994).

The fund must be a qualifying fund. The services must, viewed broadly, form a distinct whole specific to and essential for managing that fund. Merely physical or technical supplies do not qualify.

What it means

This is HMRC guidance on how it reads the existing exemption, not a change to the law. The practical test is whether the outsourced service, taken as a whole, is specific to and essential for managing a qualifying fund.

Providers whose services are largely physical or technical, such as data processing or office functions, should not assume the exemption applies. The guidance is a starting point for the analysis, not a certainty of outcome.