Ongoing Charge + VAT

Good morning,

I've started at a new firm and their clients ongoing charge includes VAT if they are in a DFM. We never did this at my old firm and I'm just wondering if this is the norm? I've tried googling but can't seem to find anything concrete.


  • It is technically correct as there is no intermediation between the adviser and the DFM (the DFM is a service, and not a Retail Investment Product). That said, many advisers are not applying VAT correctly where a DFM is concerned so it depends on the VAT risk the adviser is prepared to take and/or the advice they have received.

  • We charge VAT on our ongoing fee where we are the DFM. That said, we keep coming up against the same queries... We approached KPMG for advice, who quoted £14,000 + VAT for answers which seems extortionate! I wonder if anyone on here has any thoughts on whether VAT is applicable in the following scenarios?

    1. Recommending an Advisory GIA/ISA
    2. Recommending a Discretionary GIA/ISA
    3. Recommending a new pension with Discretionary underlying investments (e.g. Model Portfolio within a SIPP)
    4. Financial planning fees with no resulting recommendation
    5. Financial planning fees with resulting recommendation
    6. External transfer into agency of discretionary investments i.e. from one external provider's discretionary account to an account within our discretionary service
    7. Recommendation of a discretionary product where we are not the DFM e.g. we recommend the Amati AIM portfolio, which is discretionary, but we don’t manage the underlying investments so our service is technically advisory.
    8. Discretionary ongoing management fee vs Advisory ongoing management fees
    9. Hourly rate for ad-hoc client work e.g. Cashflow modelling or CGT calculations.

    Im all ears!

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