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HMRC internal manual

VAT Place of Supply (Goods)

HM Revenue & Customs
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Supplies on board ships, aircraft and trains: Intra-Community journeys: Introduction

Special rules apply to goods supplied during the course of passenger transport (other than those supplied as part of a pleasure cruise package), between places within the EC. These rules apply to journeys with stops in different Member States. Consequently they do not apply to wholly domestic journeys (to which the normal place of supply rules apply - see VATPOSG3300) or to journeys to or from destinations outside the EC.

A journey involving both intra-EC and third country legs is effectively divided up into appropriate segments. For example in the case of a journey from France to the USA via the UK, the first leg from France falls within the scope of the rules, whereas the leg from the UK to the USA is treated as an international journey (see VATPOSG4200). Similarly a journey, say involving legs between UK - Germany - Switzerland - France - Italy is treated as two separate intra-Community journeys (i.e. UK to Germany and France to Italy) with the middle leg to Switzerland being treated as an international journey.

The return leg of a journey which starts and finishes in the same Member State is treated as a separate journey. So, for example, cross-channel ferry services between the UK and France are separate journeys. In cases where there is more than one stop between the common point of departure and arrival, the return leg is the part of the journey involving Member States in which the means of transport departed from of has previously stopped.

So for example a journey comprising UK - France - Germany - UK, the return leg is Germany - UK. But if the journey were UK - Belgium - Netherlands - Belgium - UK, the return leg would be Netherlands - Belgium - UK.

In applying these rules a distinction is made between goods supplied for on-board consumption (see VATPOSG4140) and those to be taken off by passengers when they disembark (see VATPOSG4150).