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HMRC internal manual

VAT Place of Supply of Services

Establishment making or receiving the supply: VAT Groups: Single entity

When applying belonging rules, a VAT group is treated as a single entity. This treatment was confirmed by the Tribunal in Shamrock Leasing Ltd (LON/94/184), [1998] VATDR 323, (VTD 15719).

Shamrock Leasing Ltd was a UK subsidiary of the Bank of America National Trust and Savings Association (BOANTSA), which leased equipment to Security Pacific Finance (Europe) Inc (SPEF), whose business was established in the USA. SPEF then leased the equipment on to BOANTSA, whose business was also established in the USA, for use at its UK branch. The goods remained in the UK at all times. BOANTSA and SPEF were part of the Bank of America VAT Group, with SPEF gaining entry solely on the basis that it had a UK resident director. It was agreed that, on the facts, the UK part of the VAT group was a fixed establishment.


The ABC VAT group has three members. Its representative member, Company A, has its business establishment in the UK and no establishments elsewhere. Companies B and C also have their business establishments in the UK, but each has a branch, respectively in the USA and Germany. Thus, the ABC VAT Group has establishments in the UK, the USA and Germany.