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HMRC internal manual

VAT Finance Manual

Intermediaries: supplies excluded from the intermediaries exemption

Note (5) excludes a number of supplies from the exemption. These are


the supply of any market research, product design, advertising, promotional or similar services or the collection, collation and provision of information in connection with such activities



The exclusion here relates to a separate supply of any market research services etc. Any such service that is properly analysed as ancillary to a supply of exempt financial services in item 5 will be treated as exempt according to the principles set out in the ECJ judgment in the case of Card Protection Plan (‘CPP’ - Case C-349/96 - [1999] STC 270). Please see VATSC81000.


The most problematic of these are advertising and promotional activities. It has been argued that advertising or promotional services can ‘bring together’ sellers and buyers. However, our view is that they do not because not only are they specifically excluded but they also do not meet the conditions for exemption.