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HMRC internal manual

VAT Place of Supply (Goods)

Gas and electricity: Scope of the rules


The rules apply to natural gas that is located in, or imported through, a natural gas system that is either located within the EU or linked to a system within the EU. Other categories, such as bottled gas, remain subject to the normal place of supply rules for goods. All supplies of mains electricity fall within the scope of these rules.

Categories of supply

The rules distinguish between two categories of supply. These consist of supplies to wholesalers purchasing natural gas and electricity for resale (either to other wholesalers or consumers) and supplies to consumers of natural gas and electricity.

Suppliers can normally tell whether their customers are wholesalers or consumers. For example metered supplies of gas and electricity generally indicate a supply for consumption. However, in cases of doubt it is for the supplier to confirm the customer’s status.