HM Revenue and Customs Brief 58/09
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Issued 02 October 2009
VAT: Relocation of telecommunication service providers Internet service
providers and broadcasters
This Revenue & Customs Brief is of interest to all businesses within the
telecommunications, Internet service provision and broadcasting sectors who
claim to have moved or may consider moving the place of supply of their services
from the UK to another Member State. The purpose of this Brief is to explain HM
Revenue & Customs (HMRC) concerns and intended response and to encourage you to
discuss these arrangements with your Customer Relationship Manager or the
alternative contact given below.
HMRC are aware that some businesses within the telecommunications, Internet
service provision and broadcasting sectors have implemented arrangements that
claim to move the place of supply of their services from the UK to another
Member State in order to take advantage of more favourable VAT rates.
The place of supply of telecommunications, Internet service provision and
broadcasting services when provided to non-business customers in the EU is the
place where the supplier is established. Some suppliers to the UK market claim
to have reorganised their businesses so that the place of supply is no longer in
the UK but another Member State.
HMRC accepts that businesses have the freedom to choose where to locate and
to enjoy any resultant benefits.
However, HMRC will carefully examine all such arrangements. Where HMRC
considers that there are sufficient human and technical resources in the UK to
form a fixed establishment from which the services are supplied, or where the
entity purporting to make the supplies does not have a sufficient presence in
the other Member State to be established there, HMRC will mount a robust
Any business wishing to discuss their arrangements should contact either
their Customer Relationship Manager or Peter Langton at Large Business Service,
101 Victoria Street, Bristol, BS1 6DQ; Tel: 0117 9838317 in the first instance.
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© Crown Copyright 2009.
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Article Published/Sorted/Amended on Scopulus 2009-10-07 12:14:19 in Tax Articles