Value added tax – Supply of goods or services. The Upper Tribunal (Tax and Chancery Chamber) (the tribunal) allowed the appeal by Intelligent Managed Services Ltd (IMSL) against the decision of the Revenue and Customs Commissioners that the transfer of IMSL's banking support services business to Virgin Money Management Services Ltd (VMMSL), a member of the Virgin Money Group VAT group, was not a 'transfer of a going concern', with the result that the transfer gave rise to supplies of goods and services that were subject to VAT. The tribunal decided that the transfer by IMSL of the assets of its business to VMMSL had satisfied the conditions of art 5(1) of the Value Added Tax (Special Provisions) Order 1995, SI 1995/1268, and those supplies were accordingly to be treated as neither a supply of goods nor a supply of services.