Place of supply of services ― services supplied where performed

Produced by Tolley
Place of supply of services ― services supplied where performed

The following Value Added Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:

  • Place of supply of services ― services supplied where performed
  • What is the place of supply of valuation and work on goods?
  • What are goods?
  • What constitutes work on goods?
  • What is the valuation of goods?
  • What kinds of services are not considered to be work on goods or valuation?
  • What is the place of supply for cultural, artistic, sporting, scientific, educational, entertainment or similar activities / events?
  • What kinds of services are covered by the B2C rule?
  • What kinds of services are covered by the B2B rule?
  • What is the place of supply of restaurant and catering services?
  • More...

This guidance note looks at several special place of supply of services rules that result in services being treated as supplied where they are performed. The types of services affected include:

  1. services involving either the valuation of or work on goods

  2. services relating to culture, artistic, sporting, scientific, educational, entertainment or similar activities

  3. admission to cultural, artistic, sporting, scientific, educational, entertainment or similar events

  4. certain restaurant and catering services

  5. certain repair services under insurance contracts

For an overview of VAT and international services more broadly, see the International services ― overview guidance note.

For in-depth commentary on the legislation and case law, see De Voil Indirect Tax Service V3.192 and V3.198.

What is the place of supply of valuation and work on goods?

There is a special place of supply rule for valuation and work on goods. This special rule only applies to B2C supplies. The special rule for B2C services says that the place of supply for valuation and work on goods is where the work is physically performed.

In order to understand whether this special rule applies, it is important to understand it in these contexts:

  1. what is meant by goods

  2. what is the valuation of goods

  3. what is work on goods

B2B supplies are treated under the general rule, which is described in the Place of supply of services ― the general rule, relevant business persons and belonging guidance note (although see also the special rule for insurance repairs later in this guidance note).

What are goods?

HMRC takes the view that in this context goods means ‘all forms of tangible moveable property’. Goods therefore includes finished commodities and raw materials. However, it does not cover immovable property like land such as that set out in the Place of supply of services ― land-related services guidance note.

What constitutes work on goods?

Work on goods is not defined in the UK legislation, but HMRC suggests that it includes essentially any physical service carried out on another person’s goods.

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