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HMRC internal manual

VAT Place of Supply of Services

Hire of means of transport: Means of transport

Means of transport

At the 86th meeting of the VAT Committee it was agreed that means of transport included any vehicle, whether or not motorised, and any other equipment or devices designed to transport goods or persons from one place to another, which might be pulled or drawn or pushed by vehicles and which are normally designed and capable of being used for the transport of goods and persons.

This includes:

  • Motorised and non-motorised land vehicles such as cars, motorcycles, bicycles, tricycles and caravans (unless fixed to the soil)
  • Motorised and non-motorised vessels
  • Motorised and non-motorised aircraft
  • Vehicles specifically designed for the transport of sick or injured persons
  • Agricultural tractors and other agricultural vehicles
  • Non-combat military vehicles and vehicles for surveillance or civil defence purposes
  • Mechanically or electronically propelled invalid carriages
  • Trailers, semi-trailers and railway wagons.

It does not include:

  • Containers used to store or carry goods whilst being transported.

In the case of Oathplan Ltd (LON 82/85), [1982] VATTR 195, (VTD 1299), the Tribunal ruled that the supply of a timeshare in an ocean-going yacht was the sale of a beneficial interest in the yacht and not a letting on hire.