CSE3220 - How the conditions are to be interpreted: Some particular forms of Cost Sharing Groups: Partnerships have to be for profit; can they be CSG’s as a CSG can only seek ‘an exact reimbursement of Costs�?
If a ‘for profit� partnership also makes supplies that fulfil the conditions of the cost sharing exemption then they can form a CSG but the exemption would only apply in respect of those services that satisfied all the conditions of the exemption, including the ‘exact reimbursement of costs�.
This situation might occur, for example, if the partnership (as a CSG) also made supplies to third party, non-CSG (Partnership) members, where a profit element could be added and VAT would have to be charged, at the appropriate rate.