This guidance note provides information about the operation of the Tour Operators Margin Scheme (TOMS).
For an overview of the TOMS, see the Tour Operators Margin Scheme (TOMS) ― overview guidance note.
For commentary on methods of calculation of VAT under the TOMS, see De Voil Indirect Tax Service V3.593.
Information about the place of supply of designated travel services and in-house supplies made by tour operators is provided under separate headings below.
For information about the concept of designated travel services, see the Tour Operators Margin Scheme (TOMS) ― supplies covered by the scheme guidance note. Regardless of where in the world designated travel services are enjoyed, the place of supply of designated travel services by tour operators is:
the UK if the designated travel services are supplied by a tour operator from an establishment in the UK
outside the UK if the designated travel services are supplied by a tour operator
Foreign exchange issuesOverview of foreign exchange provisionsForeign exchange (FX) movements are generally taxed following the rules applicable to the underlying income, expenditure, asset or liability on which they arise, broadly as follows:Capital assetsOn a realisation basis (ie on disposal)
First year allowancesFirst year allowances (FYAs) are available on the following items:•first-year relief on qualifying new main rate plant and machinery (at 100%, which is described by HMRC as ‘full expensing’) and special rate assets (at 50%) from 1 April 2023 (companies only). These FYAs were
Entity classificationImplications of entity classificationIf a subsidiary is established, it is important to determine how it will be treated for UK tax purposes as this will determine the basis on which it is taxed. A subsidiary may either be transparent (like a partnership, where the individual