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HMRC internal manual

VAT Place of Supply of Services

HM Revenue & Customs
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Intermediaries involved in the export of goods: Law

EC law

EC VAT law relating to intermediary services in arranging the export of goods, work on goods for export, and services supplied outside the EC, is in Article 153 of the Principal VAT Directive (formerly Article 15(14) of the Sixth VAT Directive), which provides that

Member States shall exempt the supply of services by intermediaries, acting in the name and on behalf of another person, where they take part in the transactions referred to in Chapters 6, 7 and 8, or of transactions carried out outside the Community.

The exemption referred to in the first paragraph shall not apply to travel agents who, in the name and on behalf of travellers, supply services which are carried out in other Member States. 

UK law

Article 153 of the Principal VAT Directive is implemented in UK law by item 2 of Group 7 of Schedule 8 to the VAT Act 1994, which zero rates

the supply of services consisting of the making of arrangements for-

(a) the export of any goods to a place outside the member States;

(b) a supply of services of the description specified in item 1 of this Group; or

(c) any supply of services which is made outside the member States.

Note: This Group does not include any services of a description specified in Group 2 or Group 5 of Schedule 9.