ATP argued it should not have to charge VAT on its services provided to defined contribution (DC) schemes clients, as these schemes are special investment vehicles, with the ECJ agreeing.Both rulings had implications for UK sponsors, DB schemes and DC schemes with regard to VAT treatment for both investment and adminstration costs.However, HMRC did not mimic the PPG ruling regarding scheme sponsors and instead changed its guidance, potentially increasing the tax bill for some sponsors. In an update to schemes, the tax office has now said it will issue updated guidance regarding its interpretation of the ATP victory, and also the PPG case.A reassessment of its initial stance could result in scheme sponsors facing a reduction in the tax bill stemming from its DB scheme.A statement from HMRC said the body held extensive discussions with industry representatives regarding its policy on the PPG case.“In addition to this, the ECJ has issued its decision in ATP,” it said. “HMRC is now further reviewing the VAT treatment of pension scheme administration and fund management services to take account of both the PPG and ATP decisions and to consider whether to make any changes to the guidance.”A spokesman for HMRC said the body could not currently say whether the review would result in a more positive stance for sponsors.However, David Wilson, associate director for VAT at accountancy firm Baker Tilly, said the feedback HMRC received on its interpretation of the PPG ruling was that it was overly restrictive, and not following the spirit of the case.“[HMRC] may be taking a step back and thinking about what it needs to do,” he said.“This was followed by the ATP ruling, and it is just going to have to look at the whole scenario about how it impacts pension funds and how these funds are set up in the UK.“I would assume the industry would have been back to HMRC and questioned the differences between VAT law in the European Union and HMRC.”The recent changes to the DC landscape, outside of any VAT case in Europe, will have significant implications for direct tax on DC savers, and thus government revenue, he added. “It will have to re-think its positions as a result of the ATP judgment,” he said.“Hopefully, we will have some joined-up thinking for how it approaches DC schemes and auto-enrolment going forward and get one desk talking to another.” The UK tax office, HM Revenue & Customs (HMRC), could offer scheme sponsors a VAT lifeline, as updated guidance on its interpretations of recent European rulings will be issued later this year.The move from HMRC comes after recent victories for two separate entities against their own domestic tax departments regarding the charging of VAT on pension scheme services.In the Netherlands, PPG, an employer, won its case in the European Court of Justice (ECJ) against the Dutch tax authority over whether the investment management fees it pays on behalf of its defined benefit (DB) schemes should be tax exempt.A ruling regarding Danish pensions services provider ATP, on behalf of its client PensionDanmark, followed this.
Lucy Li, left, gets a high-five from her caddie, Bryan Bush, right, after finishing her round during the second round of the U.S. Women’s Open golf tournament in Pinehurst, N.C., Friday, June 20, 2014. (AP Photo/John Bazemore)PINEHURST, N.C. (AP) — Lucy Li’s friends back in California have been filling her inbox with emails.That’s the only way they can reach her at the U.S. Women’s Open.The 11-year-old is too young for a cellphone.“They’re like, ‘Oh, you’re famous now,’” she said, laughing.Li made quite an impression at Pinehurst No. 2 — even if she didn’t make it to the weekend. The youngest qualifier in the history of the tournament mostly held her own at the Women’s Open.For the second straight day, a couple of rough holes proved to be her undoing.Hurt by a double bogey and a triple bogey, Li shot her second straight 8-over 78.According to her caddie, this week was never about her score.“She was here for the experience and the opportunity to play with the best players in the world,” caddie Bryan Bush said. “She proved that she can.”Li was 22 strokes behind leader Michelle Wie and 19 behind Lexi Thompson, who both know about playing the Women’s Open at a young age.Wie’s first was in 2003 when she was 13. In 2007, Thompson became the youngest to qualify at age 12 — until Li supplanted her.“I hope she’s having a blast out there,” Wie said.All eyes were on the pre-teen from the Bay Area who showed a beyond-her-years knack for bouncing back from mistakes and rough holes.She bounced back from her roughest hole — the par-4 13th — with one of her best.Li’s tee shot on 13 landed in some thick weeds, and she missed the ball when she tried to punch it out. After a brief chat with USGA President Tom O’Toole, she took a drop and her shot from that rough ricocheted off the green and near the seating area.After she chipped to about 15 feet, she pushed that putt wide right and tapped in for her second triple bogey of the tournament.She came back strong: Li birdied the 14th — her favorite moment of the tournament — and closed her round with pars on three of her final four holes to match her opening-round score.“I’m really happy with how I bounced back from the big numbers,” Li said.Marlene Bauer’s place in tournament history as the youngest player to make the cut remained safe: She was 13 in 1947 in the second Women’s Open before going on to become one of the founders of the LPGA Tour.___THE CUT LINE: A couple of the LPGA Tour’s most recognizable names didn’t make it to the weekend.Cristie Kerr, who won the Women’s Open the last time it was held in the North Carolina sandhills in 2007, was at 10-over — missing the cut by one stroke.Cheyenne Woods — Tiger’s niece — had six bogeys during her 75 and was at 13-over. And Morgan Pressel was at 12-over following her 75.Two other players who began the day in danger of missing it used strong rounds to earn tee times on Saturday and Sunday.Defending champion Inbee Park, who shot an opening-round 76, had three birdies on the back nine of her 71 that moved her to 7-over.“It’s never too far back in the U.S. Open, I think,” Park said. “Anything is possible on this golf course.”Lydia Ko joined her at 7-over after two late birdies during her 71.___AMATEUR HOUR: Minjee Lee was a fan at last year’s Women’s Open, spending the week hanging around with her hero — fellow Australian Karrie Webb — at Sebonack in New York.“It’s like the best experience ever,” Lee said. “So yeah, it was good last year.”This one’s even better.Playing the Women’s Open for the first time, the amateur moved to 1 over after her second-round 71 that pushed her into a tie for third behind Michelle Wie and Lexi Thompson.Now, after spending most of her life looking up to Webb, now it’s Webb who’s looking up at her — on the leaderboard.“It is my first and I’m in contention,” Lee said. “So I can’t ask for anything more, really.”Said Webb: “Another Aussie flying the flag. So that’s good. She’s a great little player.”___OFFLINE: Na Yeon Choi doesn’t Google herself anymore.Not after the 2012 Women’s Open winner read all those news stories about her back home in South Korea while she pushed to become the world’s top-ranked player.“I read all the Internet news in Korea and sometimes that gave me a lot of pressure,” Choi said, adding that now, “I try not to search my name on the Internet.”After climbing to No. 2 in the world rankings last year, she said she “tried so hard to be No. 1, that gave me a lot of pressure.“Last year, when I go to a tournament, I only think about winning,” she added. “I can’t control the winning, but I think that all the pressure affected my game in a negative.”Choi came to Pinehurst at No. 15 in the current rankings and was 1 over through two rounds.___EARLY EXITS: Two players withdrew Friday.Jane Park withdrew midway through the second round with a back injury. She shot a 75 in the first round and had five bogeys and a double bogey in nine holes in the second round.That came a few hours after the USGA said Lizette Salas withdrew due to food poisoning. Salas had eight bogeys in an opening 78.___Follow Joedy McCreary on Twitter at http://twitter.com/joedyap