Commentary

V4.251C Transport of goods, handling, intermediary and other services

Part V4 Exemption, zero-rating and reduced rates

V4.251C Transport of goods, handling, intermediary and other services

V4.251C Transport of goods, handling, intermediary and other services

This paragraph considers the scope of zero-rating in connection with the following categories of supply which are zero-rated under VATA 1994, Sch 8, Group 8:

  1.  

    •     the transport of goods1

  2.  

    •     handling services2

  3.  

    •     air navigation services3

  4.  

    •     pilotage services4

  5.  

    •     salvage and towage services5

  6.  

    •     surveying and classifying services6

  7.  

    •     intermediary services7

  8.  

    •     handling and storage services8

  9.  

    •     designated travel services9

  10.  

    •     intra-EU transport services10

For an overview of all the supplies covered by this VATA 1994, Sch 8, Group 8, see V4.251.

Transport of goods—transport (zero-rating)

VATA 1994, Sch 8, Group 8, item 5 provides for zero-rating of the transport of goods from a place within the EU to a place outside the EU, or vice versa, to the extent that the services are supplied within the UK11.

Transport services supplied within the UK

For the place of supply of services rules for the transportation of goods, see V3.189.

Evidence required to support zero-rating of transport services

Evidence to support zero-rating may, in the view of HMRC, comprise12:

  1.  

    •     Contracts or agreements

  2.  

    •     Consignment notes

  3.  

    •     Bills of lading

  4.  

    •     Certificates of shipment

  5.  

    •     Air or seaway bills

  6.  

    •     Customs declaration forms

supported by

  1.  

    •     Inter-company correspondence

  2.  

    •     The customer's order documentation

  3.  

    •     Payment details

  4.  

    •     Sales invoices

  5.  

    •     Advice notes

In Cartrans13, the CJEU considered that EU legislation precluded 'a tax practice of a Member State under which the exemption from value added tax for, respectively, the supply of transport services directly connected with

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