“66. In order to be characterized as exempt transactions for the purposes of points 3 and 5 of Article 13B, the services provided by a data-handling centre must, viewed broadly, form a distinct whole, fulfilling in effect the specific, essential functions of a service described in those two points. For ‘a transaction concerning transfers’, the services provided must therefore have the effect of transferring funds and entail changes in the legal and financial situation. A service exempt under the Directive must be distinguished from a mere physical or technical supply, such as making a data-handling system available to a bank. In this regard, the national court must examine in particular the extent of the data-handling centre's responsibility vis-à-vis the banks, in particular the question whether its responsibility is restricted to technical aspects or whether it extends to the specific, essential aspects of the transactions.” 13. Bookit provided card handling services to customers of Odeon cinemas. The focus in that case was Bookit’s role in card transactions where cinema tickets were being purchased, and in particular its relationship to the merchant acquirer. The CJEU referred to previous decisions and stated as follows: “38. In that regard, the Court has previously held that a transfer is a transaction consisting in the execution of an order for the transfer of a sum of money from one bank account to another. It is characterised in particular by the fact that it involves a change in the legal and financial situation existing, on the one hand, between the person giving the order and the recipient and, on the other, between those parties and their respective banks; and, in some cases, between those banks. Moreover, the transaction which produces the change is solely the transfer of funds between accounts, irrespective of its cause. Thus, a transfer being only a means of transmitting funds, the functional aspects are decisive for the purpose of determining whether a transaction constitutes a transfer within the meaning of Article 135(1)(d) of the VAT Directive (see, to that effect, the judgments of5 June 1997 , SDC , C‑2/95, EU:C:1997:278 , paragraph 53, and of28 July 2011 , Nordea Pankki Suomi , C‑350/10, EU:C:2011:532 , paragraph 25). 39 . Further, the wording of Article 135(1)(d) of the VAT Directive does not in principle preclude a transfer from being broken down into separate services which then constitute ‘transactions concerning’ transfers within the meaning of that provision (see, to that effect, judgment of5 June 1997 , SDC , C‑2/95, EU:C:1997:278 , paragraph 64). While it is not inconceivable that the exemption at issue may extend to services which are not transfers per se, the fact remains that that exemption can relate only to transactions which form a distinct whole, fulfilling in effect the specific, essential functions of such transfers (see, to that effect, judgment of5 June 1997 , SDC , C‑2/95, EU:C:1997:278 , paragraphs 66 to 68). 40 . It follows from the foregoing that, in order to be characterised as a transaction concerning transfers within the meaning of Article 135(1)(d) of the VAT Directive, the services at issue must, viewed broadly, form a distinct whole, fulfilling in effect the specific, essential functions of a transfer and, therefore, having the effect of transferring funds and entailing changes in the legal and financial situation. In that regard, a service exempted under the VAT Directive must be distinguished from the supply of a mere physical or technical service. To that end, it is relevant to examine, in particular, the extent of the liability of the supplier of services, in particular the question whether that liability is restricted to technical aspects or whether it extends to the specific, essential aspects of the transactions (see, to that effect, judgments of5 June 1997 , SDC , C‑2/95, EU:C:1997:278 , paragraph 66, and of28 July 2011 , Nordea Pankki Suomi , C‑350/10, EU:C:2011:532 , paragraph 24). 41. It must also be stated that, since the functional aspects are decisive to the determination of whether a transaction concerns a transfer for the purposes of Article 135(1)(d) of the VAT Directive, the test that makes it possible to distinguish a transaction that has the effect of transferring funds and bringing about changes in the legal and financial situation within the meaning of the case-law cited in paragraphs 38 to 40 of this judgment, which falls within the scope of the exemption concerned, from a transaction that does not have such effects and therefore, is outside its scope, is whether the transaction under consideration causes the actual or potential transfer of ownership of the funds concerned, or fulfils in effect the specific, essential functions of such a transfer (see, to that effect, judgment of28 July 2011 , Nordea Pankki Suomi , C‑350/10, EU:C:2011:532 , paragraph 33).” 14. The CJEU stated that the card handling services did not fall within the scope of the exemption. The reasoning for this conclusion appears at [51] - [57] as follows: “51 . It follows from all the foregoing that the provider of a card handling service, such as that at issue in the main proceedings, plays no specific and essential part in achieving the changes in the legal and financial situation that are the result of a transfer of ownership of the funds concerned and that, according to the Court’s case-law, can be said to be characteristic of a transaction concerning payments or transfers that is exempted under Article 135(1)(d) of the VAT Directive, but does no more than provide technical and administrative assistance for the obtaining of information and the communication of that information to its merchant acquirer, and to receive, by the same means, the communication of information that enables it to effect a sale and to receive the corresponding funds. 52 . In that regard, it must be recalled that the fact that such a service is provided by electronic means, and in particular the fact that the transmission of the settlement file entails the automatic triggering of the payments or transfers under consideration, cannot alter the nature of the service provided and, therefore, does not affect the application of the exemption at issue (see, to that effect, judgment of5 June 1997 , SDC , C‑2/95, EU:C:1997:278 , paragraph 37). 53 . A card handling service, such as that at issue in the main proceedings, which accordingly consists, in essence, in an exchange of information between a trader and its merchant acquirer, with a view to receiving payment for a product or service offered for sale, cannot fall within the scope of the exemption provided in Article 135(1)(d) of the VAT Directive for transactions concerning payments and transfers. 54 . It may be added, first, that such a service cannot be deemed to be, by its nature, a financial transaction for the purposes of Article 135(1)(b) to (g) of the VAT Directive, unless the view is taken that any trader that takes steps necessary for the receipt of payment by debit card or credit card is undertaking a financial transaction for the purpose of those provisions, which would render that concept meaningless and would be contrary to the requirement that VAT exemptions must be interpreted strictly. 55 . Second, if the exemption provided for in Article 135(1)(d) of the VAT Directive were to be granted to a card handling service, such as that at issue in the main proceedings, that would be at odds with the purpose of the exemption for financial transactions, which is to alleviate the difficulties connected with determining the tax base and the amount of VAT deductible and to avoid an increase in the cost of consumer credit (judgment of19 April 2007 , Velvet & Steel Immobilien , C‑455/05, EU:C:2007:232 , paragraph 24, and order of14 May 2008 , Tiercé Ladbroke and Derby , C‑231/07 and C‑232/07, not published, EU:C:2007:332, paragraph 24). 56 . If a card handling service, such as that at issue in the main proceedings, is subject to VAT, there are no such difficulties. In particular, the tax base, which corresponds to the consideration received in exchange for that service, namely the fee charged to the purchaser of the ticket for that service, can readily be determined, and such a transaction does not involve the provision of any credit to the purchaser by the provider of that service. Such a service cannot therefore properly be the subject of an exemption under Article 135(1)(d) of the VAT Directive. 57 . In the light of all the foregoing, the answer to the questions referred is that Article 135(1)(d) of the VAT Directive must be interpreted as meaning that the exemption from VAT provided there for transactions concerning payments and transfers is not applicable to a ‘card handling’ service, such as that at issue in the main proceedings, supplied by a taxable person, the provider of that service, where an individual purchases, via that service provider, a cinema ticket which the service provider sells for and on behalf of another entity, and which the individual pays for by debit card or by credit card.” 15. NEC was a similar case, where it provided a card processing service for individuals who used cards to purchase tickets for events run by third parties at the NEC. The conclusion was summarised at [46]: “46. …the provider of a payment card processing service, such as that at issue in the main proceedings, does not participate specifically and essentially in the legal and financial changes giving rise to a transfer in the ownership of the funds concerned and permitting, in accordance with the Court’s case-law, the transaction to be characterised as a transaction concerning payments or transfers which is exempt under Article 13B(d)(3) of the Sixth Directive, but merely applies technical and administrative means which enable it to collect information and communicate that information to the merchant acquirer bank and to receive, by the same means, the information which enables it to make a sale and receive the corresponding funds.” 16. In DPAS, the taxable person managed dental plans which were supplied to dentists. The dental plans involved arrangements between dentist and patient under which the dentist agreed to provide dental care to the patient. The patient agreed in return to pay a specified monthly amount, agreed between the dentist and his patient. The plans also included other services such as insurance cover. DPAS collected the monthly payment from patients by direct debit and then paid sums to the dentist less an amount it retained as the charge for its services. There was a contract between DPAS and the dentist for the provision of dental payment plan services, which was subject to VAT, and a contract between DPAS and the patient for the provision of dental payment plan ‘facilities’ which DPAS treated as exempt. 17. The CJEU stated that the services supplied by DPAS to patients were not exempt as transactions concerning payments. The conclusion was stated as follows: “ 41 . DPAS does not itself carry out the transfers or the materialisation in the relevant bank accounts of the sums of money agreed in the context of the dental plans at issue in the main proceedings, but asks the relevant financial institutions to carry out those transfers... 42. As the Advocate General has also observed in point 51 of his Opinion, a supply of services such as that at issue in the main proceedings is merely a step prior to the transactions concerning payments and transfers covered by Article 135(1)(d) of the VAT Directive. … 51. In the light of all of the foregoing considerations, the answer to the first question is that Article 135(1)(d) of the VAT Directive must be interpreted as meaning that the VAT exemption which is provided for therein for transactions concerning payments and transfers does not apply to a supply of services, such as that at issue in the main proceedings, which consists for the taxable person in requesting from the relevant financial institutions, first, that a sum of money be transferred from a patient’s bank account to that of the taxable person pursuant to a direct debit mandate and, second, that that sum, after deduction of the remuneration due to that taxable person, be transferred from the latter’s bank account to the respective bank accounts of that patient’s dentist and insurer.” 18. Most recently, these decisions of the CJEU have been considered by the Upper Tribunal in Target Group Limited v HM Revenue & Customs[2019] UKUT 340 (TCC) . That case concerned loan administration services supplied by Target to Shawbrook Bank Limited. The services included giving instructions to BACS to transfer funds from a borrower’s account to Shawbrook’s account and maintaining Shawbrook’s ledger account for each borrower’s loan. Target contended that these services “effected” the transfer of funds and were exempt as transactions concerning payments or transfers. The Upper Tribunal reviewed various authorities including SDC and DPAS. It stated at [74] and [75]: “74. The decision of the CJEU in DPAS is, in our judgement, clear and unambiguous. Where the relevant service at issue involves the giving of an instruction to a financial institution to effect a payment, it does not constitute an exempt supply even though it may be a necessary step in order for the payment to be made. 75. In the present case, every transfer of funds made by a borrower to Shawbrook is effected by the borrower’s financial institution debiting the borrower’s account by the relevant amount and Shawbrook’s bank crediting a matching sum to Shawbrook’s account (together with matching debits and credits effected by other banks sitting between one or other of the borrower’s and Shawbrook’s bank and the Bank of England, as explained by Laws LJ in FDR at [37]). Target’s role is limited to passing the necessary information to BACS to enable it to give the relevant instructions to the borrower’s bank and Shawbrook’s bank so that the transfer of funds can take place. That is indistinguishable from the role played by Denplan - so far as payments made by the patients are concerned - in giving the relevant instruction to the patient’s bank pursuant to the direct debit mandate in order for patient’s bank to cause the payment to be made to Denplan’s bank.” 19. The Upper Tribunal went on to consider the Court of Appeal’s decision in Customs & Excise Commissioners v FDR Limited[2000] STC 672 . Target submitted that it effected the transfer of funds in the same way as FDR. In FDR, the taxpayer supplied credit card services to issuing banks and acquiring banks. It maintained accounts, posting credit and debit entries on each, effecting payments to merchants and reconciling accounts between issuers and acquirers under a netting-off procedure. The Court of Appeal held that a “transfer of money means no more nor less than the entry of a credit in the payee’s account and the entry of a corresponding debit in the payor’s account”