This paragraph covers the special place of supply rules that apply to the transportation of goods or passengers.
For an overview of the place of supply of services rules more broadly, see V3.181.
Place of supply of passenger transportation—legislation
The general rule for determining where a supply of services is made (see V3.183) is varied by VATA 1994, Sch 4A, para 2 in relation to the transportation of passengers.
VATA 1994, Sch 4A, para 2 provides that the transportation of passengers (and any accompanying luggage or motor vehicles) is made in the country in which the transportation takes place, having regard (where more than one country is involved) to the proportion of distances covered in each country.
Transportation which takes place partly outside the territorial jurisdiction of a country is to be treated as taking place wholly in the country if1:
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• it takes place in the course of a journey between two points in the country (whether or not as part of a longer journey involving travel to or from another country), and
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• the means of transport used does not (except in an emergency or involuntarily) stop, put in or land in another country in the course of the journey between those two points
A pleasure cruise (including a cruise wholly or partly for education or training) is regarded as the