Commentary

V4.136A Exemption for finance—money and related intermediary services

Part V4 Exemption, zero-rating and reduced rates

V4.136A Exemption for finance—money and related intermediary services

V4.136A Exemption for finance—money and related intermediary services

VATA 1994, Sch 9, Group 5, items 1 and 5—scope of the exemption

Exemption is extended to1:

  1.  

    •     the issue, transfer, or receipt of, or any dealing with money

  2.  

    •     the issue, transfer, or receipt of, or any dealing with any security for money, or any note or order for the payment of money, and

  3.  

    •     the provision of intermediary services in relation to the above (whether or not any such transaction is finally concluded) by a person acting in an intermediary capacity

The term 'money' is not defined, save to say that it includes currencies other than sterling2. It appears to comprise 'currency, bank notes and coins, in sterling or any other currency used as legal tender in a financial transaction, but not platinum nobles'3.

The term 'security for money' is not defined, but it 'would appear to be used in its ordinary sense, that is to say some instrument whereby the indebtedness of the borrower to the lender is by some means 'secured''4. It has been described as 'a document under seal or under hand at a consideration containing a covenant, promise or undertaking to pay a sum of money', and such document 'does not have to be either 'marketable' or 'transferable' or 'negotiable''5. In Wiltonpark6, the Upper Tribunal held that vouchers purchased by patrons of a night club and used to pay for the services of dancers amounted to securities for money: 'The voucher is given to the dancer by the

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