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HMRC internal manual

VAT Place of Supply of Services

Where performed services: sporting services


Sporting services are taxable where the event takes place when supplied B2C. B2B they fall within the general rule (VATPOSS06000).

They include

  • individual sports persons appearing at an event for a fee (‘appearance money’)
  • organisation of sporting events such as races and tournaments, and
  • provision of race-prepared cars to racing teams or drivers, comprising a package including the hire of the car and support services to ensure the optimum maintenance and operation of the car throughout a series of races (however, the services of vehicle hire alone would not fall within this section (VATPOSS11000).

Identifying a supply of sporting services

When considering the position of sporting services you must examine very carefully whether there is in fact a supply and, if so, the nature of what is supplied. If prize money is received by a sports person this is generally not the consideration for a supply and is therefore outside the scope of VAT: see the VAT Sport manual (VSPORT).

Distinguishing a supply of sporting services from sponsorship

Where a payment is described as sponsorship, it is necessary to consider the nature of the service being provided. For example, sponsorship may be received as consideration for product endorsement or publicity appearances which would constitute a supply of advertising services within the general rule (unless supplied to customers outside the EU - see VATPOSS13200).

If payments are described as ‘sponsorship’ they may or may not refer to supplies: see the VAT Supply and Consideration manual (VATSC) and Notice 701/41: Sponsorship.