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HMRC internal manual

VAT Transport

Transport: Intermediary services (ship and aircraft brokers and other agency services): Law

The law applying the zero-rate to intermediary services in arranging many of the services described in other parts of Group 8 is in item 10 of the Group:

  1. The making of arrangements for -

  2. the supply of, or of space in, any ship or aircraft;
  3. the supply of any service included in items 1 and 2, 3 to 9 and 11; or
  4. the supply of any goods of a description falling within items 2A or 2B.


Sub-paragraph (c) was added to the item by the VAT (Ships and Aircraft) Order (SI 1995/3039), with effect from 1 January 1996, under the same provision which introduced the zero-rating for ship and aircraft parts in items 2A and 2B.

Group 8, item 10 is based on Principal VAT Directive (Directive 2006/112) Article 153.

153 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.