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HMRC internal manual

VAT Place of Supply of Services

Where performed services: work on goods

The place of supply of valuation services or work carried out on any goods is where the services are physically performed when it is provided B2C. The reference to goods in this context means moveable tangible property and does not mean land and/or property.

Valuation of goods includes the services of loss adjusters, average adjusters, motor assessors, surveyors and other experts in connection with an insurance proposal or claim, where these consist of simply valuing goods. The final compilation of a related report in a different country from that where the goods are located will not change the place of supply from the country where the valuation work itself was performed.

However, this does not include either a comprehensive loss adjustment services, a mere inspection, or where the goods are examined as part of the advisory service.

The term work on goods is defined in law only to the extent in Implementing Regulation EC 1777/2005, which is the assembling of another person’s goods (except where the goods being assembled become part of immoveable property). However, the term work on goods also includes

  • alterations and repairs
  • calibrations
  • cleaning
  • insulating
  • lacquering
  • painting
  • polishing
  • resetting jewellery
  • sharpening
  • varnishing
  • waterproofing
  • processing and manufacturing
  • repairs, cleaning, or restoration
  • assembling components or parts
  • cutting of precious stones
  • restoration of antiques and paintings
  • repair of freight containers
  • services relating directly to the ‘covering’ (that is attempting to secure the pregnancy) of a mare, also called ‘nomination to stallions’.

    The hearing of the VAT Tribunal appeal by Banstead Manor Stud Ltd (LON 78/412), [1979] VATTR 154, (VTD 816) considered the liability of supplies of stud services to a French customer. The crucial point was whether the expert services supplied by the stud farm, of arranging the covering of the mare at the correct times, under medical supervision, together with feed and keep, over the period of several months necessary to procure a pregnancy, came within the definition of work on goods, even though the stallion itself was not owned by Banstead and was supplied separately to the customer by its owners. The Tribunal found that the term work on goods comprised all the elements directly required to procure the pregnancy of the mare, and that this included the services of the stud farm.

  • breaking in of young horses (for example training yearling racehorses to the stage where they can be ridden safely in races), however, actual racing is not accepted as training.
  • restoration of classic cars.

This list is not exhaustive, but you should use the principles set out in this paragraph, together with the examples, in deciding whether any particular service amounts to work on goods.