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UK VAT explained including when businesses are required to register for VAT, HMRC rules and how VAT is applied to different types of goods and services and when VAT can be recovered. VAT (Value Added Tax) is a tax on consumption and is added to the sale of goods and services supplied by VAT Registered businesses. Not all products and services sold attract VAT and there are a number of VAT rates or categories as follows: Standard Rated 20% (taxable) Reduced Rate 5% (taxable) Zero Rated (taxable) Exempt Outside The Scope Depending on the goods being sold or services being provided, one of the categories above will be applied to the sale. Standard Rated Goods and Services Standard Rated goods and services are goods sold or supplied by VAT registered businesses and include 20% VAT. Therefore invoices to customers will include 20 % VAT. Standard Rated services fall into the taxable services bucket and where businesses make taxable sales and exceed or are likely to exceed £90,000 , they are required by law to Register for VAT. Examples of Standard Rated goods and services include: Fuel Professional Services such as Legal and Accountancy Computers and Mobile phones Hotel Accommodation No Domestic Energy Alcohol Restaurant food and hot takeaways Goods and Services with Reduced Rate VAT of 5% Reduced rate VAT of 5% is mainly applied within the domestic fuel and construction industry. Examples of Reduced Rate VAT at 5% include: Domestic / residential energy bills (Gas & Electric) Gas fired boiler installation Radiator Connection or re-connection to the gas mains Renovating a dwelling that has been empty for at least 2 years Zero Rated VAT Goods and services supplied as Zero Rated VAT are taxable supplies but without VAT applied. Therefore invoices generated and sent to customers for zero rated supplies will not include VAT. Examples of Zero Rated goods and services include: Children's clothing Books Sewerage services supplied to domestic or industrial customers Water supplied to domestic households Insulation Take away - cold food Note: where businesses make sales of goods and services to non UK business customers, these can also be treated as Zero Rated in some instances as they are deemed outside the scope of UK VAT but are classed as taxable services which carry the right to deduct Input VAT. (Please see place of supply button) Exempt Goods and Services Exempt supplies of Goods and Services unlike standard rated and zero rated are not taxable supplies. Exempt supplies are listed in the VAT Act 1994 Sch 9 and include the following: Postal Services Insurance Land and Property Rental Education Financial Services VAT Registration Businesses in the UK (including Isle of Man) are required to register for VAT If the value of their Taxable Turnover (standard rate, reduced rate and or zero rated supplies) in the preceding 12 months or less goes over the registration threshold of £90,000 If the value of their taxable turnover (standard rate, reduced rate and or zero rated supplies) is likely to exceed £90,000 in the next 30 days if the business is based outside the UK and supplies goods or services in the UK or are expected to in the next 30 days. (Threshold does not apply here) If a businesses is being acquired by a VAT registered business as a going concern If you make distant sales into Northern Ireland and exceed the annual threshold. Note: Businesses include Sole Traders, Partnerships, Limited Companies, Clubs, Associations. What is Taxable Turnover Standard Rated Sales of goods and services Zero Rated Goods and Services Reverse Charge Output VAT Any Goods or Services you barter or part exchange The value of any goods you have used for private use Property services supplied (rent and service charges) where you have opted to tax the building. What is not Taxable Turnover Sales of capital items such as buildings , machinery, cars Exempt supplies Voluntary Registration Yo u can apply to HMRC for voluntarily registration if: you are making taxable supplies where their value is under the £90,000 threshold. This will allow you to recover VAT expenses incurred. You are intending to make taxable supplies in the near future Register - onl ine here Tax Point R ules Tax points are the specific points in time when sales of goods or services take place and are governed by rules set out by HMRC. VAT registered businesses must account for VAT within the period the tax points for their sales occur. So if a tax point occurs in March and the businesses next VAT return period is January to March then the VAT on the sale will have to be included within the quarter ending March VAT return. Basic Tax Point Goods - The date when you send them to your customer or the customer takes them away or for goods assembled at a suppliers premises, when the goods are made available to the customer Services - The date when the service is performed — it’s normally taken as the date when all the work except invoicing is completed Actual Tax Point The basic tax point will be overridden if an actual tax point is created. An actual tax point is created when: An invoice is issued or payment is received (whichever is first) before the basic tax point. An invoice is issued up to 14 days after the basic tax point You do not have to follow the 14 day rule, but if you decide not to you must tell HMRC by writing to the VAT Written Enquiries Team . If you wish to have an extension of the 14 day rule, then you must apply to HMRC by writing to the VAT Written Enquiries Team , giving your reasons. Note: Failure to tell HMRC about extending the 14 day rule will result in the tax point reverting to the basic tax point. Continuous Supplies of Services If you supply services on a continuous basis and receive payments regularly or from time to time, there’s a tax point every time you issue a VAT invoice, or receive a payment, whichever happens first. If payments are due to be made at regular intervals (for example, by banker’s order or direct debit), you can issue a VAT invoice at the start of any period of up to one year (provided that more than one payment is due in the period) to cover all the payments due in that period. For each payment you should set out the: VAT-exclusive amount Date on which the payment is due Rate of VAT VAT payable If you decide to do this, you do not have to account for tax on any payment until the date on which it is due, or date you receive it, whichever happens first. Your customer must not reclaim, as input tax, any VAT shown on the VAT invoice until the date on which the payment is due, or you have received the payment, whichever happens first. The same procedures apply to continuous supplies of goods, in the form of water, gas and electricity. Goods supplied on sale or return, approval or similar terms When you supply goods on sale or return, for example, they have not been sold and you still own them until such time as they’re adopted by your customer. Adoption means that the customer indicates a wish to keep them. Until your customer does so, your customer has an unqualified right to return them at any time, unless you have agreed a time limit. You may have fixed a time limit of adoption of less than 12 months from the date when the goods were sent. If a time limit has: Been fixed for a period of 12 months or less, then the Basic Tax Point is the date the time limit expires Not been fixed or fixed for a period of more than 12 months, then the Basic Tax Point is 12 months from the date when the goods were sent Note: In either case if your customer adopts the goods before the time limit expires the date of adoption becomes the basic tax point. Also the basis tax point as mentioned above will be overridden by the actual tax point on the date an invoice issued by the business providing the goods or the date payment is received for the goods, which ever is earlier. If you receive a payment which is not returnable, this will normally indicate that the goods have been adopted. The payment of a deposit required as a condition of delivery — which is repayable if the goods are returned — does not constitute adoption. Finally, It is a businesses responsibility to make sure that its customers notify them promptly when they have adopted goods. Goods taken for personal or other non-business use Goods that are taken out of a business: Permanently for non-business use will have a basic tax point on the date when the goods are taken or set aside for this purpose Temporarily for non-business use, but they’re still part of its stock or business assets, then a tax point is triggered each time they’re used or — if the non-business use continues over a period of time — on the last day of each tax period that the goods are used or made available for that purpose VAT Returns VAT Registered businesses that make supplies of goods and services are required to file their VAT returns to HMRC either monthly or quarterly (depending on VAT scheme) to pay over the Output VAT collected on sales to their customers and also to recover any Input VAT they have incurred on supplies they have purchased for operating their business. The difference between the Output VAT collected and the Input VAT incurred will form the basis as to whether VAT is payable or recoverable from HMRC. VAT collected on Sales greater than VAT incurred on purchases = Payment due to HMRC VAT incurred on purchases greater than VAT collected from customers = Recovery of VAT from HMRC Any exempt and zero rated supplies a firm makes to its customers or purchases from its suppliers also need to be included on the VAT Returns in boxes 6 and 7 respectively. Partial Exemption - VAT Recovery In addition to Output VAT that is collected by a business on its sales and then paid over to HMRC, businesses can also recover VAT on expenses they incur. The recovery of VAT depends highly on the nature of the supplies being made by the business. Business is only making Taxable Supplies (Standard rated, reduced rate or zero rated) - then the Input VAT incurred on its purchases is directly attributable to its taxable sales and can be fully recovered from HMRC. Business only makes Exempt Supplies - Then it cannot recover any of the input VAT incurred on purchases as the input VAT is directly attributable to supplies of exempt goods or services. Businesses making a mixture of Taxable and Exempt Supplies - This type of business is known as a partially exempt business and because not all of its supplies are taxable, it can only recover a calculated percentage of the input VAT it has incurred. Partially Exempt Businesses - will be required to calculate their partial exemption recovery percentage or rate and then apply this rate to their pool of input VAT that they have incurred. The standard method for calculating the partial exemption recovery rate is as follows: Taxable Sales (Standard, Zero, Reduced Rate) / Total Sales (Standard, Zero, Reduced Rate, Exempt) = VAT Recovery Rate Percentage % Example - Standard Rated Sales £1,000, Zero Rated Sales £500, Reduced Rated Sales £200 and Exempt Sales £2,000 £1,000 + £500 + £200 / £3,700 = 46 % RR If the input VAT pool is £20,000, then the business can recover £9,189 from HMRC via its VAT return. Note: Many larger and more complex businesses (such as banks) will have Partial Exemption Special Methods which will have been formulated specifically for their business and agreed with HMRC. Many businesses will have multiple internal business areas and products and as such using the standard method may not be suitable. Once formulated businesses will be required to adhere to their agreed Partial Exemption Special Methods and keep HMRC up to date on any internal business restructures that might affect the agreed method. HMRC - has the right to issue a Special Method Override where they believe the existing method in use does not produce a fair and reasonable level of VAT recovery. Annual Input VAT Adjustments As part of the VAT return process partially exempt businesses are required to complete annual Input VAT adjustments to ensure the correct amount of VAT has been recovered from HMRC for the overall year. Normally businesses will file quarterly VAT returns which include VAT recoverable for the quarter. The recovery of VAT on the quarterly returns will be based on the input VAT allocated between Taxable and Exempt sales for the quarter or based on the previous years VAT recovery rates which are being provisionally used for the current year until the annual adjustment is completed. So VAT returns completed during the year are actually provisional in terms of the recovery of VAT. As such at the end of the year input VAT recovery will need to be revisited to: Review how input VAT has been used in the business to see if there has been any change in use. (Taxable / Exempt) Recalculate VAT Recovery Rates based on the current years sales data Review input VAT allocations to different areas of the business Once the above process has been completed, the recalculated input VAT recovery for the whole year will then be compared with the input VAT reclaimed on the quarterly returns. Any under or over recovery of VAT will then be refunded or repaid to HMRC normally via the first VAT return of the following year. From a business perspective, it maybe important to carry out mid year reviews of the VAT recovery by looking at aspects such as actual VAT incurred and Actual VAT recovery rates so as to not have large swings in irrecoverable VAT which can affect P&L where the input VAT throughput is significant. (Most relevant to partially exempt businesses where VAT recovery is high). Reverse Charges Where firms purchase services from non UK suppliers that would normally have VAT applied in the UK, they will have to self account for reverse charge VAT in the UK. The purpose of this measure is to ensure UK companies have a level playing field competitively and as such ensure companies do not make their purchases abroad just to avoid paying 20% VAT. The following purchases would attract Reverse Charge VAT Legal and Accountancy services Software Advertising Consultancy For example if a UK company purchased legal services from a company in France for £1,000 then the UK company would have to include £200 on its UK VAT return as output VAT and will equally it will able to include £200 as recoverable input VAT. Note: as mentioned under partial exemption above, the level of input VAT recoverable by a business will depend on the type of sales it makes. If a firm only makes taxable (standard and zero rated supplies), then it will be able to recover the full £200 reverse charge VAT which is payable to HMRC. In this case, as the reverse charge VAT payable is equal to the reverse charge VAT recoverable and as such there is nothing to pay HMRC. If the firm also made exempt supplies to it's customers and the French legal fee charge was not related to a specific taxable supply being made by the UK company, then it would only be able to recover a portion of the £200 reverse charge VAT based on its Partial Exemption Recovery rate. On its VAT return the business would enter £200 in box 1 (Output VAT) and £200 in box 4 (input VAT recoverable) and thus box 5 ( VAT payable of recoverable from HMRC ) would be nil. The net values of the services would go in box 6 (net outputs) and (net inputs) respectively. For more information on reverse charges, please click on reverse charge button on the home page. Pre VAT Registration Expenses Where a business buys goods or services before it registers for VAT, to support taxable business activities when it is registered, it can recover the tax provided that: in the case of goods (either stock for resale or fixed assets), the goods remain on hand at the date of registration and will be used in the newly registered business. These goods must have been bought within the time limits that are set out in regulation 111; for businesses with a registration date after 1 April 2010 the time limit will be 4 years in the case of services the supply was made not more than six months before the date of registration. Six months represents a period in which it is deemed that services obtained will relate to business activity carried on at the time of registration. Tax incurred on goods on hand at registration (other than capital items - see below) cannot be deducted if the VAT was incurred outside of the time limits set out in regulation 111. This includes VAT incurred on services performed on those goods. If a business is given a backdated registration date this becomes the relevant date for working out the extent of the time limits. Businesses are not required to reduce the VAT deducted in respect of pre-registration use of fixed assets. For example, VAT incurred on a van purchased three years before registration and used before and after registration would be recoverable in full, subject to the normal rules on VAT deduction. You can only reclaim VAT on purchases for the business now registered for VAT. They must relate to your ‘business purpose’. This means they must relate to VAT taxable goods or services that you supply. Please see below HMRC link for more information. VIT32000 - How to treat input tax: pre-registration, pre-incorporation and post-deregistration claims to input tax under regulation 111 - HMRC internal manual - GOV.UK (www.gov.uk) Required VAT Records and Accounts All taxable persons must keep and preserve certain records and accounts. This VAT record-keeping requirements that anyone who is registered for VAT must comply with includes: The VAT account What records must be kept Maintaining and preserving records For more information see Record keeping (VAT Notice 700/21) . -Contains public sector information licensed under the Open Government Licence v3.0. UK VAT Explained - What is VAT & when businesses need to register for VAT

World VAT Guides. Global VAT guides on how VAT and GST is applied in different countries. Including VAT and GST rates, VAT rules, the VAT and GST liability of goods and services. GLOBAL VAT Guides - Country VAT Guides - How VAT Applies VATDIGITAL.COM - Explore our Global VAT Guides for information and updates on VAT and GST rules and how they are applied to locally and international transactions including to non domiciled entities. Australian - GST Austria - VAT Canada - GST / HST China - VAT Denmark - VAT Germany - VAT EU - VAT French - VAT Estonia - VAT Ireland VAT Italy - VAT Japanese Consumption Tax Show More Argentina - VAT Chile - VAT Jersey - VAT Show More VAT For Businesses - EU Explore Luxembourg - VAT Nigeria - VAT Ghana - VAT South Africa - VAT Netherlands - VAT Norway - VAT Portugal - VAT Singapore - GST Spain - VAT Israel VAT Saudi Arabia - VAT Switzerland - VAT Show More Poland VAT India - VAT Kenya VAT Show More Ecommerce - Online Traders - EU One Stop Shop Explore

Banking and VAT - Explore how VAT applies to products and services in Banking and the the different VAT allocation and recovery models used. Introduction The world of banking can cover a broad spectrum of areas that can typically operate under a banking institutions umbrella. Traditionally banking was represented by retail and commercial banking where the main businesses was to provide a sanctuary for individual and commercial savings and at the same time provide loans and finance to individuals and businesses. However nowadays, many banks also offer Investment Banking and Private Banking services. Listed below are a number of services provided by the different areas of banking. (The list is not exhaustive) Investment Banking Inv estment Banking services are mainly provided to Large Public and Private Companies, Pension Funds, Governments, other Banks and Private Equity etc. Services Provided: Mergers and Acquisition Advisory - Advising on strategic transactions such as Acquisitions, Mergers, Joint Ventures, Leveraged Buyouts, Business Restructures Trading Platforms - That Facilitate the trading of Bonds (debt), Equities, Swaps, Options, Futures, Debt Financing - Bond issuance, Securitisation (Asset & Mortgage Backed securities), Loans, Liability Management Equities (stock)Lending - Acting as intermediary for a company that lends shares for a fee and a company that pays a fee to borrow the shares possibly for shorting. Initial Public Share Offerings - Advising and raising finance for the issue of shares to the general public Debt Underwriting - Arranging and underwriting the issuance of debt Share Underwriting - Underwriting shares during Initial public offerings (basically a guarantee to buy a portion of unsold shares) Risk Management - Providing clients with management solutions to better manage interest rate and foreign exchange risks and exposures Research - Carrying out general market, micro and macro economic research or specific sector research for clients for a fee Commodities Trading - Trading in physical commodities such as Oil, GAS, Electricity, Metals and Precious Metals such as Iron, Nickel, Gold, Silver, Palladium Private Equity - The pooling of funds to use to make acquisitions for investment purposes Market Data - The provision of real-time electronic data to companies, markets etc, to enable and assist decision making Wealth Management and Private Banking Wealth Management and Private Banking is mainly provided to private Individuals and smaller companies. Services Will include: Portfolio Management - Discretionary and Non Discretionary management of client assets Private Banking - A package of banking services for affluent individuals with levels of bespoke services for different grades of affluence. E.g. £100K to 500K, £1M to £10M, £10M to £50M etc. International Banking - A package of banking services offered to Expats etc Fund Management - The Management of pooled funds in Unit Trusts, OIEC's or through a fund supermarket owned by the bank or externally Model Portfolios - Bespoke portfolios that are designed specifically to achieve the investment goals of a group of clients Financial Advisory and Planning - Retirement Planning, Estate Planning, Executor and Estate Administration, Trustee Services, Pensions, Tax Advisory Financing - Trade, Real Estate, Boats. Yachts, Private Jets Execution Only - Retail share investing Credit Cards - Providing credit card services to clients Corporate Banking Corporate Banking is mainly provided to larger commercial enterprises where turnover exceeds between £5M - £10M. Some of these services are listed below. Business Banking - Providing business bank accounts to corporate clients International and Trade Finance - Providing international import and export financing, letters of credit Asset Financing - Providing financing solutions for acquiring cars, boats, planes, property Debt Factoring and Invoice Discounting - Proving working capital solutions by taking over a client's debtors for a fee to provide clients with smother cash flow. Inventory Finance - Providing finance to intermediary distributors of trucks, Tractors, Construction Equipment, Cars Cash Management - Finding the best return on client cash balances by moving the funds around to get the best rates Foreign Exchange - FX Trading Corporate Credit Cards - Providing corporate credit cards to firms Business Development loans - Loans to help businesses grow Retail Banking Retail Banking is mainly provided to individuals (general public) and small and medium sized businesses. Services include: Traditional Banking - The provision of bank accounts (current and savings) Cheque Clearing - The clearing and processing of cheques with other banks Mortgages - The provision of residential mortgages Personal Loans - Loans to consumers to buy cars, domestic appliances, Business Loans - Loans to businesses to fund growth and acquisitions Debit and Credit Cards - Provision of personal Debit and Credit Cards Insurances - Travel insurance, Residential Insurance Banking Income Most of the income generated by banks will either be: Fees Received Interest Received Commission Received VAT Liability of Services Supplied by Banks The VAT liability of banking income will depend on: Type of Service being provided to clients and customers The Place of Supply of those Services The Type of Client (business or non business) services are being provided to The Specific VAT rules governing the services being supplied Whether the Service is to a Branch, a VAT Group member or not The VAT liability will either be: Standard Rated (20%) Zero Rated Exempt Outside the Scope Type of Service Being Provided Financial Services are largely Exempt from VAT under the Financial Services VAT Exemption (VAT Act, Schedule 9, Group 5, 1-9). As such, many services offered by Banks will be Exempt when supplied in the UK. Services that are not covered under the Finance Exemption will be taxable at the Standard Rate (20%) when supplied in the UK by banks and other financial institutions . The Place of Supply of Services and the Type of Client The place of supply of services as mentioned under the place of supply tab, is determined largely by whether the supply is to a customer or client in business or whether the supply is to a non business customer . Business Customer Supplies to customers in business (VAT Registration is normally sufficient evidence) Supplies to customers that have both business and non-business activities such as charities, local authorities and government departments Non Business Customer A customer who is not in business Private individual Charity, Government Department or other body which has no business activities Services Supplied to Customers in Business Supplies to clients in business will be covered under the B2B (Business to Business) General Rule and thus the place of supply will be where the customer or client belongs . (Clients Country of Operation). Services Supplied to Non Busin ess Customers Normally supplies to Non business customers under the place of supply rules will be covered under the B2C (Business to Customer) General Rule and thus the place of supply will be where the supplier belongs. However there are special rules in place for particular B2C services (including Financial Services) that treat the place of supply of those services that would normally be taxable in the UK as being supplied where the customer or client belongs. List of Services Supplied by Banks and their VAT Liability As mentioned above, banks provide a broad spectrum of services and below is a list of B2B and B2C services both within and covered by the Financial Services VAT Exemption and those that are not covered. Note: The services listed below that are Exempt when provided to clients in the UK are within the scope of the Finance Exemption and the services that are Standard Rated are not. Below we have listed the main types of services offered by banks and the VAT liability for each service which depends largely on the type of client B2B or B2C and the service being offered. Retail "Day to Day Banking The Traditional service offered by banks to the retail sector (general public) of accepting cash deposits and providing advances and loans, cheque processing and clearing to customers where interest in earned by the banks as income is: Exempt when supplied to a B2B and B2C customer in the UK Outside the scope of VAT (with recovery) when provided to Non UK B2B or B2C customers. Insurance Services Many banks will offer insurance products such as home insurance, contents insurance, motor breakdown insurance to its customers. These services will be: Exempt when supplied to a B2B and B2C customer in the UK Outside the scope of VAT (with recovery) when provided to Non UK B2B or B2C customers. Corporate Finance (Mergers and Acquisitions) This service is mainly offered by Investment Banks and will involve providing Advisory Services in relation to potential acquisitions or mergers between companies. These services are: Standard Rated when provided to B2B and B2C customers in the UK Outside the scope of VAT (with recovery) when provided to B2B and B2C non UK Customers Corporate Loans (Including Mortgages) Corp orate Loans can be offered by retail banks to smaller businesses or by banks providing corporate banking services to larger businesses that turnover millions of pounds a year. The granting and advancing of credit falls within the Financial Services Exemption and is: Exempt when supplied to a B2B and B2C customer in the UK Outside the scope of VAT (with recovery) when provided to Non UK B2B or B2C customers. Execution Only Share Transactions Many banks will offer online trading platforms that facilitate execution only trading in securities such as equities whereby members of the public or companies can buy and sell shares. Execution only trading means the bank will act on the clients instruction to either buy or sell shares (with no advisory or recommendations involved) and the VAT liability is as follows: Exempt when supplied to a B2B and B2C customer in the UK Outside the scope of VAT (with recovery) when provided to Non UK B2B or B2C customers. Arranging the Issue or Placement of Securities Banks (Investment) involved in the arrangement or placement of shares, rights issues, coordination of an issue of shares where there are a number of participants, this service will be: Exempt when supplied to a B2B customer in the UK Outside the Scope of VAT (with recovery) when provided to a B2B customer Safe Custody Some banks offer safe custody services whereby clients can store documents such as share certificates, Gold, Silver, titles etc for a fee. This Fee is: Standard Rated (20%) for B2B and B2C when supplied to customers in the UK Outside the Scope of VAT (with recovery) when provided to a B2B or B2C customer Global Custody Global Custody may contain safe custody but will include a package of additional services such as the collection of dividends, interest etc. Where the service contains additional activities as described above along with safe custody, then the VAT liability will be: Exempt when supplied to a B2B and B2C customer in the UK Outside the scope of VAT (with recovery) when provided to Non UK B2B or B2C customers. Nominee Services Nominee Services whereby client shares will be held in the name of the bank on behalf of them. These services are: Exempt when supplied to a B2B and B2C customer in the UK Outside the scope of VAT (with recovery) when provided to Non UK B2B or B2C customers. Stock Lending Stock lending describes a situation where one person, the ‘lender’, transfers to a second person, the ‘borrower’, the legal title, along with all the dividends and rights, to securities. The borrower agrees to return to the lender, at a later date, an equivalent number of the same securities as those received. Stock lending is : Exempt when supplied to a B2B and B2C customer in the UK Outside the scope of VAT (with recovery) when provided to Non UK B2B or B2C customers. Share Underwriting Share underwriting where a bank will receive a commission or fee for guaranteeing to buy unsold shares during an Initial Public Offering (IPO) is : Exempt when supplied to a B2B customer in the UK Outside the scope of VAT (with recovery) when provided to Non UK B2B customers. Note: Any shares onward sold by the Bank will also follow the same VAT liability as above. Tax, Legal, Accountancy Adhoc services that may be provided by some banks or financial institutions are not covered by the Finance Exemption and are thus: Standard Rated 20% (taxable) when supplied to a B2B and B2C customer in the UK Outside the scope of VAT (with recovery) when provided to Non UK B2B or B2C customers. Portfolio Management Portfolio Management services normally offered by the Private Banking or Wealth Management arms of banks for individual clients can be split into discretionary or non discretionary. These services can be offered either internally or via third party Investment Managers. (Portfolio Management does not fall within the Financial Exemption like the management of funds such as AUT's of OEIC's as the service is not a collective investment where large numbers of clients funds are pooled together and invested) Discretionary Portfolio Management is where the Manager will make investments on behalf of the client based on their goals and risk appetite Non Discretionary Portfolio Management is where the client makes their own investment decisions and may take recommendations or advice from the manager but will ultimately decide on the investments the manager should make on their behalf. Normally the Portfolio Manager (the bank) or the external Portfolio Manager will charge an Annual Management Fee which will be: Standard Rated 20% (taxable) when supplied to a B2B and B2C customer in the UK Outside the scope of VAT (with recovery) when provided to Non UK B2B or B2C customers. The Investment manager as part of the contract may apply a transaction charge (commission) for executing trades or buying and selling securities on behalf of the client. If these charges as part of the contract are a separate supply of dealing charges, then the VAT liability is as follows: Exempt when supplied to a B2B customer in the UK Outside the scope of VAT (with recovery) when provided to Non UK B2B customers. If these charges as part of the contract are bundled together as a single fee for Investment Management, then the VAT liability is as follows: Standard Rated 20% (taxable) when supplied to a B2B and B2C customer in the UK Outside the scope of VAT (with recovery) when provided to Non UK B2B or B2C customers. Model Portfolios A Model Portfolio Service is a tailor made service designed by an Investment Manager(s) for a group of investors with the same investment aims. Funds are invested in a diverse range of assets and asset classes with the aim of reducing risk for clients. This service has traditionally been treated in the same way as normal portfolio Management by applying VAT on fees charged. However many portfolio managers are removing VAT from their fees charged to UK clients on the basis of a recent case (Tatton) where HMRC refunded a substantial amount of VAT on fees charged for their model portfolio service on the basis that the funds were pooled similar to collective investments. Futures Contracts - (Financial) Financial Futures are standardised derivatives contracts offered by and traded by Investment banks (as Futures Exchange Members) and allow investors to: Speculate on the price movement of an underlying financial instrument (Stocks, Interest Rates, Currencies, Indexes). Hedge against the movement of the price of a financial instrument. ( mainly companies that use the future contact as a hedge against to protect their own financial instruments ) Financial Futures can either be cash or non cash settled . Cash settled means there is no actual delivery of the financial instrument at expiry whereas Non Cash Settled means there is actual delivery of the instrument. Futures contracts are highly liquid and can be traded on Futures Exchanges prior to the expiration date. Income generated by banks from Futures contracts (commission earned by banks) is: Exempt from VAT when sold or traded with counterparties in the UK Outside the scope with recovery when sold to a non UK counterparty Financial Forward Contracts Financial Forwards Contracts (forwards) are similar in nature to Futures Contracts in that they both require the buyer and seller to set the quantity of a financial instrument and the date of delivery or expiry. However the major difference between the two is that whilst the Futures Contract is normally a standardised contract traded on a futures exchange , a Forward is a non standardised private agreement between a buyer and seller OTC. Note both futures and forward can be traded privately off exchange Over The Counter (OTC). Income /commissions generated by banks as broker to investors in Forward Contracts is: Exempt from VAT when sold or traded with counterparties in the UK Outside the scope with recovery when sold to a non UK purchaser Financial Options Options are Financial derivatives that are based on the value of underlying securities such as stocks, bonds, currencies and give the buyer the right to buy (call option) or sell (put option) the underlying asset on a specific date and and specific price. Unlike futures or forwards there is no obligation to actually buy the underlying asset. As such a premium is paid for the right to buy the options. Most options are equity options and are traded on exchanges and if exercised, settled via centralised clearing houses. Income generated by banks trading or facilitating the trading of options is: Exempt from VAT when sold or traded with counterparties in the UK Outside the scope with recovery when sold to a non UK counterparty Foreign Exchange Trading (FX) (Spots) Banks often act as brokers offering FX currency trading (Spots) to clients and charge commission. The Income generated will be: Exempt from VAT when sold or traded with counterparties in the UK Outside the scope with recovery when sold to a non UK counterparty Research Banks (investment) often have research departments that compile and sell investment research normally to companies to assist with their investment decisions. This research is: Standard Rated 20% (taxable) when supplied to a B2B and B2C customer in the UK Outside the scope of VAT (with recovery) when provided to Non UK B2B or B2C customers. Trading Platforms Many larger banks may offer trading platforms "dealer systems" to their clients which allows them to buy and trade securities or provides live market data such as share prices or foreign exchange rates. Systems that purely provide market data services to users are taxable as follows: Standard Rated 20% (taxable) when supplied to a B2B and B2C customer in the UK Outside the scope of VAT (with recovery) when provided to Non UK B2B or B2C customers. Systems that allow users to insert bits and offers for securities and Match the parties anonymously and finalise the deal will be be covered under the Intemediary Exemption and Exempt from VAT. If the system does not match the parties on an undisclosed anonymous basis then the service will be vatable at the standard rate 20% Hire Purchase Banks may offer their customers Hire Purchase which allows them to pay installments over a set period for goods such a motor vehicles or washing machines with the option to make a final payment for the goods at the end of the payment term. Where the goods and finance are provided by the bank, then there will be two supplies one of goods and one of credit. For the supply of goods, the customer will be charged standard rated VAT at 20% immediately for the supply of the goods and the ongoing supply of credit repayable in installments will be Exempt. Factoring & Invoice Discounting Some banks may offer Factoring and or Invoice Discounting to clients. Factoring is where a factoring company (bank) purchases the outstanding debtor balances from a client for a charge and can either be recourse or non-recourse. Recourse is where the client maintains the responsibility and bears all the risks of debtor non payment. If the debtor goes bankrupt or the bank can't collect the funds from the debtor, then the client will have to buy back the debt from the bank. Non Recourse factoring means that the factoring company bears greater risk if a debtor defaults on its debt. Another feature of factoring is that it means the bank or factor can maintain a credit control facility for the debts and collect the debts directly from the debtors. Invoice discounting is where the bank provides a loan against the clients outstanding debtor balance for which the client can draw down against. The Debtor will be unaware that the client is using this facility. There can be many charges levied by the factor (bank) some of which may be Standard Rated 20% and others Exempt. Below is a list of the possible charge types and their VAT liability. Arrangement and or Activation Fee - Standard Rated 20% VAT if provided to UK Businesses and Zero Rated if provided to Non-UK business Discount Fee or Charge for Credit - Exempt if provided to UK Businesses and Zero Rated if provided to Non-UK business Service Charge - Standard Rated 20% VAT if provided to UK Businesses and Zero Rated if provided to Non-UK business Non Utilisation of Loan Facility Fee - Exempt if provided to UK Businesses and Zero Rated if provided to Non-UK business Early Termination Fee - Standard Rated 20% VAT if provided to UK Businesses and Zero Rated if provided to Non-UK business Funds Transfer Charges - Exempt if provided to UK Businesses and Zero Rated if provided to Non-UK business Legal and other Admin Fees - Standard Rated 20% VAT if provided to UK Businesses and Zero Rated if provided to Non-UK business Private Equity / Strategic Investments Banks can also as part of their business use its own funds along with other corporate clients or individuals to invest (or build up stakes) in external businesses with the aim of holding those businesses for investment purposes. I.e. Capital growth. Income generated from those investments can be dividends which are outside the scope of VAT or in the case where the bank is actively managing those investments and charging a fee to the other participant, this will be Standard Rated. BANK COSTS AND VAT Banks by their nature are not actively trading in physical goods and as such most of their costs will be professional or resource (staffing) related. Costs - Plus VAT For Banks, VAT will typically be incurred on professional service and IT related costs such as Information Technology Software and Software Development Virus and Anti Malware Protection Hardware such as Computers, Servers, Screens, Keyboards, Mouses Telecommunications and Equipment Market Data Brokerage Consultancy Services Legal Services Electricity Administration Furniture and Fittings Security Property Rental (opted properties) Other Asset Purchases for Hire Purchase or Inventory Finance Office Supplies Exchange Membership Licence Fees Exchange Admin Fees Exchange Access Fees Gate way / Terminal Connectivity Swift Messaging Advertising Sponsorship Research Costs - No VAT Banks will have significant Non Vatable Costs due to the large numbers of staff they employ. Wages and Salaries Income Tax and National Insurance Bonuses Property Rental (non opted) Pension Contribution Clearing Systems and VAT Banks may have a variety of systems (especially the larger banks) to record Income and cost and the associated output and input VAT respectively. Most of the time the number of different systems will be dictated by the number of acquisitions the banks have made over the years where they inherit different systems from each acquisition. However many will have core well established market leading systems (Accounts Payable and Accounts Receivable) such as SAP to record and account for VAT on the bulk of their sales and purchases and which can easily be integrated into into Tax Engines to churn out VAT Returns. From a VAT perspective, the most important and critical aspect for systems in today's digitalized world is their ability to apply the correct VAT code to specific transactions and their flexibility for full end to end automation of the VAT Accounting, Reporting and Recovery process. Sales and VAT Reporting Services provided by Banks to their customers (both internal and external) will need to be treated and categorised correctly for VAT to ensure: The correct amount of Output VAT is included on their VAT Returns and paid to HMRC The correct amount of VAT is included on sales invoices Their Partial Exemption VAT Recovery Rates and Actual VAT Recovery is accurate The best way to ensure the accuracy of above is to: Have a highly automated billing system with links to the static data system that stores clients name, type and location / country of operation details Have a digitalised VAT process that auto allocates income to the correct Partial Exemption sectors Have well trained front office billing staff who understand VAT and the differences created by billing to UK vs Non UK customers Have robust controls around the review and authorisation of invoices Have a Team of Tax or VAT specialist to monitor, advise and carry out regular reviews of the VAT billing Process Have multiple level VAT return reviews and investigate and seek explanations for any quarter on quarter exceptional variances Costs and VAT Reporting VAT incurred by banks on costs is often very significant and as such it will be high on management's radar to ensure: VAT allocation is aligned to cost allocation VAT recovery from HMRC is optimised VAT is recovered in accordance with the Partial Exemption Method agreed with HMRC VAT Recovered is allocated back to the correct business area (Equities, Corporate Finance, Corporate banking, Private Banking etc) VAT incurred on costs can be split into: Front Office VAT - VAT that is directly incurred and attributable to specific business areas such as Corporate Banking, Mergers and Acquisitions, Fixed Income Bond Trading, Corporate Loans, Foreign Exchange Back Office or Infrastructure VAT - General VAT incurred for all business areas such as IT, Consultancy, Electricity, Security, Administration. Partial Exemption Methods and VAT Allocation Most banks will be partially exempt in that they provide taxable and exempt services to their clients and as such will have agreed methods with HMRC for allocating and recovering VAT incurred on their costs. Note: Partially exempt means that not all of the VAT incurred on costs will be recoverable from HMRC, only a portion. These agreements are known as Partial Exemption Special Methods (PESM) and will be different for each bank. They contain precise details of how VAT will be allocated to the different agreed sectors (Equities, Investment Banking, Retail Banking, Derivatives etc) and also how VAT recovery should be calculated. So the agreements will stipulate how VAT will be allocated. For example based on the: Firms internal Cost Allocation Methodology Business Area Activity Business Area Front Office Headcount Others VAT Recovery The recovery of VAT in banks will be based on specific formulas as stipulated in the Partial Exemption Special Method. Most will be in the following format: VAT Pool X Taxable Sales (Standard Rated + Reduced Rate + Zero Rated / Total Sales (Taxable + Zero Rated + Exempt) = VAT Recoverable % Note: The amounts in the above categories can be in the form of sales values , no of transactions , no of sales credits etc and will depend on what is agreed in the PESM Looking at the above formula, it can be seen that the level of VAT recovery will be dependent on the ratio of taxable sales to total sales. The more exempt sales a bank has the lower the VAT recovery The greater the taxable sales a bank has the greater the VAT recovery will be. VAT Recovery Methods Due to the complex operational nature of banks and their varied products, most will have agreed Partial Exemption Special Methods (PESM) with HMRC. These agreements prescribe in detail how input VAT will be allocated and the methods to be used in the various areas of the bank to recover VAT. Standard Method - is simply a values method as shown below but may have special rules depending on the products supplied : VAT Pool X Value of Taxable Sales / Total Value of Sales = VAT Recoverable % Partial Exemption Special Methods (PESM) - Can include Values, Transaction Counts, Sales Credits etc as agreed with HMRC for the different business areas or sectors within a bank. There are a number of typical Partial Exemp tion S pecial Methods (agreed method with HMRC for the allocation and recovery of input VAT) in use by Banks namely: Values Based Method Transaction Count Method Sales Credits Method Mixture of Above The method used will depend on the complexity of the banking business. A purely Retail or Corporate banking business will be able to use the standard values method which uses revenue values to calculate the VAT recovery rate (RR) to be applied to the pools of input VAT to determine the level of VAT the bank can recover from HMRC. The Recovery Rate Calculation is: Values Based Method (Std Rated + Reduced Rate + Zero Rated) (Std Rated+ Reduced Rate+ Zero Rate + Exempt ) = RR Note the method can be used in conjunction with the other methods Pros Data usually easy to extract from Accounting System Easy to review, audit and verify source data Uncomplicated or time consuming Cons Assumes larger Loan book areas use higher input VAT (not always the case so input VAT allocation needs to be accurately based on use) Not alwa ys suitable for more complex operations like Investment Management, Wealth Management and Investment Banking Transaction Count Method This method uses transactions instead of values by tallying up each transaction for example each receipt of a fee or commission (less any refunds) in each business area . For example equities, credit, FX, Bonds or Fixed income etc. As this method measures each business transaction, it can be more accurate in terms of calculating the correct VAT recovery rate for more complex business areas. The Recovery Rate Calculation is: No of Trans (Std Rated + Reduced Rate + Zero Rated) No of Trans (SR+ R Rate + Zero Rate + Exempt ) = RR Pros More suitable for complex banking operations Transactions are more reflective of use than values Likely to produce a more accurate VAT recovery rate than the values method Cons Extracting the data and maintaining the reports and systems that support this can be time consuming and tedious. Annual reviews of data sources and IT sign-offs will be required to ensure accuracy of the transaction count data Takes much longer to compile and review the data to be able to calculate the annual adjustment Sales Credit Method This is a more modern method which uses the internal Sales Team reward and incentive system which is based on the level of sal es each team generate. Basically noti onal sales credits (values) are allocated to each product sales team based on the level of sales generated for each product. It is a values based system albeit not actual sales values. The ke y here is tha t the notional values allocated are reflective of the level of sales in each team and credits allocated are reviewed at multiple levels to ensure the rewards to the product teams Credit, Equities, FX, FI are reflective of performance . The Recovery Rate Calculation is: Sales Credits Non UK (Zero Rated) Sales Credits (Non UK (Zero Rated) ) + Exempt (UK)) = RR Note: This method will mainly be used for calculating the partial exemption recovery calculation for exempt type services such as equities, bonds, derivatives trading etc as the sales credit data can be split into UK / Non UK notional values and thus exempt / zero rated. Using it for banking would be tricky as the sales credits allocated to the UK would be for a mixture of taxable and exempt products and a further split at this level may not be readily available or reliable enough for the PESM calculation. Pros Data collection is much easier than the traditional values and transaction count method as it's usually readily available because the data is used internally for annual reward. Don't have to source data from multiple sources compared to other methods. Potentially quicker PESM calculation Values directly linked to activity Cons Reliance on non finance area to provide data which can increase bottle neck risks . Queries have to be referred back to different teams HMRC VAT Notice 706 ( Extract on Special Methods) 6. Special methods 6.1 The definition of a ‘special method’ A sp ecial method is any calculation, other than the standard method, that enables you to calculate how much of your input tax you may recover. It must only allow you to recover the input tax on your purchases to the extent that you use these purchases to make taxable rather than exempt supplies now or in the future. Supplies that are made outside the UK that would be taxable if in the UK and certain exempt supplies to non-UK customers also gives the right to recover input tax, but there are special rules (see section 9). A special method is unique to your business, and you can develop it to deal with your particular business circumstances. However, you must not use a special method, nor change a special method that you are already using, without our written approval. With effect from 1 January 2011 you may apply for a special method (known as a ‘combined method’) which combines your business or non-business (other than private use) and partial exemption calculations. See paragraph 7.1 for more information. 6.2 Get approval for a special method You cannot change your method without our prior approval. You must continue to use your current method, whether that is the standard method or a special method, until we approve or direct the use of another method or direct termination of its use. You can get approval for a special method by using one of these options: the online service in writing to the VAT Written Enquiries team at BT VAT, HM Revenue and Customs, BX9 1WR, United Kingdom by email to: PESM@hmrc.gov.uk From 1 August 2022, you will no longer be able to send a special method request to the PESM@hmrc.gov.uk email address. Only write to the Written Enquiries team if you are unable to use the online service. You must explain clearly how your proposed method will work, you should see Appendix 2 in this guide. When you propose a special method you must include a declaration that the method is fair from its effective date of application, and for the foreseeable future so that from its effective date a fair amount of input tax is recovered. If we subsequently find your declaration to be incorrect we may serve a special method override notice (see section 8 for more information about the special method override notice) to override the method so that from its effective date input tax would be recovered according to the use of purchases in making taxable supplies. A declaration is incorrect if 2 conditions are not met, the: method does not produce a fair and reasonable attribution of input tax to taxable supplies resulting in an unfair over-recovery of input tax person signing the declaration knew or ought reasonably to have known this at the time they made the declaration If you apply to change your existing special method this is an application for a new method and you will also have to provide a declaration. The declaration can be made using the template at Appendix 1. All approvals and directions of special methods must be given in writing by HMRC. If we decide to approve your method, we will set it out in a format which includes standard terms and conditions. A covering letter will be sent to you with the method asking you to check that it accurately reflects your proposal. Unless you raise concerns within 30 days we will assume that you’re content with the approved method. If we decide not to approve your method we will write to you explaining the reasons why, and where appropriate, invite you to make further or modified proposals. If you make a further or modified proposal you will need to make a new declaration. If there are specific aspects of the method that you need to discuss, you may do so before making a firm proposal, saving the need for an additional declaration. You will usually be allowed to use the new method from the start of the tax year in which the declaration to the written application (being the approved application) is received. See section 8 about the special method override notice. 6.3 What a special method can contain A special method is unique to your business and can contain any calculations or stages that are needed to make sure it is fair and reasonable. All special methods should: reflect all your business activities provide for direct attribution of input tax to taxable supplies provide for direct attribution of input tax to exempt supplies identify residual input tax calculate the element of residual input tax that relates to taxable supplies calculate the element of residual input tax that relates to exempt supplies allow you to determine the total input tax that you can recover 6.4 Dealing with different parts of your business separately in your special method If a method calculates a separate recovery rate for each sector it is commonly referred to as a ‘sectorised’ method. Partial exemption sectors might arise naturally from the way your business organises itself, for example, if your business has discrete areas, activities, or even accounting centres, in which you use your input tax differently. This is most likely where your business is large and complex, or where your business consists of a VAT group of separate businesses. Very often, the best way to get an accurate partial exemption recovery method in the least burdensome way is to base it on your internal cost accounting system used for management reporting purposes. However, there are circumstances where this is inappropriate, for example, where costs are reported on a marginal basis. If you propose a method based on internal cost accounting, you will need to explain the kind of system being operated and what controls are in place to make sure that it’s accurate. 6.5 How to determine the recovery rate for residual input tax When you use the standard method the percentage recovery rate for residual input tax is calculated using the values of supplies made by your business. When you use a special method you can determine your percentage recovery rate using other allocations and apportionments. You can even use a different type of calculation for each sector if you have a ‘sectorised’ method. 6.6 Examples of allocations and apportionments Some examples are: output values numbers of transactions staff time or numbers inputs or input tax floor area costs allocations management accounts This list is not exhaustive and if you use any of the above you must make sure that the resulting calculation produces a result that is a true reflection of the use to which your input tax is put. The most common apportionment methods are output values and number of transactions, although some of the others can work in some circumstances. However they are more common as allocation methods between business sectors. More information can be found in PE30000 — VAT partial exemption guidance . 6.7 Rounding in special methods You must calculate the percentage recovery rate produced in your special method to 2 decimal places. 6.8 Changes in your circumstances If you operate a special method and there’s any change in your business circumstances, or if you’re a VAT group and there’s any change in the group membership that may have a significant impact on the amount of input tax you can claim, it’s important that you tell us immediately. If your method is no longer suitable for your business, you should propose an alternative method. If you fail to propose a suitable method, we may direct you to use a specified method. In some circumstances a special method override notice (see section 8) may need to be served. 6.9 HMRC imposing a method We have the power to direct a business to use a particular method or to stop using an existing special method. These powers are only used in circumstances where we are unable to identify a mutually satisfactory method, or where the VAT system is being abused. Directions are made in writing and apply from the date they’re given, or from a specified future date. If you disagree with the issue of a direction you can ask for either of the following: a review of our decision an appeal to be heard by an independent tribunal There’s more information about what you can do if you disagree with our decision in a HMRC factsheet and customer guidance which can be found at in HMRC1: HM Revenue and Customs decisions — what to do if you disagree . 6.10 Annual adjustments when using special methods You have to follow a similar procedure to the standard method to calculate the annual adjustment for a special method (see section 12). 6.11 Gaps in special methods A special method is said to have a ‘gap’ whenever it fails to specify how to deal with an amount of residual input tax. Gaps most commonly arise when business circumstances change after methods have been approved. Residual input tax falling into a ‘gap’ is to be recovered to the extent that the purchases on which the input tax is incurred are used in making taxable supplies. Where the treatment of input tax on purchases is only partly covered by the method, that is, part of the input tax falls into the ‘gap’, only that part of the input tax not covered by the method comes under these rules. This does not mean that we think that methods with ‘gaps’ are acceptable but merely sets out how to cope with gaps if they arise in future. Once a gap has arisen, we expect that you will make suitable proposals for a new method that takes account of the gap and any other known faults in your current method. VAT and Inter- Company Recharges VAT Group Members - If a bank operates within a VAT Group structure, then most of the Internal inter entity recharges between VAT Group members will be outside the scope of VAT and thus VAT will not feature on any invoicing between the entities. However problems can arise where non UK entities recharge into the UK where the Non UK entity is not within the UK VAT Group (by way of being a branch of a VAT group member) and thus significant Reverse Charges can become applicable on cost recharges to UK entities for: Staff Consultancy Intangible Assets (Goodwill) IT Costs If the Reverse charge VAT has not been budgeted for locally, then businesses can end up having significant irrecoverable VAT costs hitting their P&L where they are not able to fully recover the reverse charge VAT from HMRC. International Banks and Sourcing Banks that have global operations will tend to want to ensure that where supplies of IT and other services are purchased: Services are provided by local suppliers where possible to the entities using the services Services are billed and delivered to the entities using the services The contracts state who is purchasing the service, consuming the service, ultimately paying for the service This can avoid situations where the services are billed to the UK and incur UK Reverse Charge VAT but actual consumption and use of the services occurs in non UK locations. Although full recovery of the VAT is possible, it can often mean lots of administration to achieve. Recharging of Professional Costs to Clients As part of providing services to clients, banks will often incur legal and other professional fees which they will then recharge on to their clients. The VAT element of the cost will also often be recharged depending on whether the banks can recover the costs from HMRC. The recovery of the VAT incurred on these cost by the bank will depend on the services being supplied to the associated client and the location of the client. See below table for illustration. Vendor Location UK VAT Service Type VAT Recovery By Bank Location of the client UK UK 20% Taxable (advisory) Full VAT Recovery UK / Non UK Non UK 20% RC VAT Exempt Irrecoverable VAT UK Non UK 20% RC VAT Exempt Full VAT Recovery Non UK Where the bank can achieve full recovery of VAT as in the above examples, it can then bill the clients for the net value of the professional services invoice. Where the VAT is irrecoverable by the bank from HMRC in the above examples, it may then seek to recover this VAT from the clients by billing the client the net value of the invoice plus the VAT incurred or reverse charged ( VAT self accounted for to HMRC). Risk Management and Controls One of the main areas of focus in Banks and more specifically Finance and Tax will be around having an adequate and robust control environment to ensure the accuracy of internal and external reporting and to prevent errors. A large part of this will be to create and maintain a strong control environment from the top downwards and ensure this is embedded within the culture of the bank. In Terms of VAT , the following list of activities and controls will all help to minimise the risk of errors. Up to date VAT Coding within front office billing systems Up to date VAT coding within the accounts payable system Up to date and thorough procedure notes for VAT return preparation Multiple reviews of all manual VAT related Journals Multi-level review of all VAT Returns and Annual Adjustments Automating manual processes to eliminate human error Elimination of spreadsheet based VAT reporting (MTD VAT Compliant) Annual or bi-annual E2E Integrity Review of VAT reporting process and systems Regular multilevel reviews of VAT accounts Service Level Agreements between VAT Team and Finance / OPS Regular training of VAT staff supported by decision trees and diagrams Ensuring regular engagement with Finance to ensure VAT is considered and built into new systems Regular review of Partial Exemption Methods and Partial Exemption calculations Adequate New Product and Trade sign-off procedures Impact Assessments for all changes to systems Automated VAT Return Production including VAT allocation and input VAT recovery Error Correction Notifications to HMRC followed up with remedial actions and controls to prevent error repitition Risk reporting process that highlights impact of errors on P&L and the required action to remediate Maintaining good relationships and ensuring transparency with HMRC Key Current VAT Related Issues In Banking Electronic Invoicing Making Tax Digital (MTD) HMRC Review - Establishment and Branches ( Fixed Establishment or Brass Plate) European Commission - Review of Financial Services & insurance Model Portfolios - wealth and Investment Managers Skandia and Danskie Bank (reverse skandia) CJEU rulings Sub - Participation vs Syndication The VAT Act 1994 - Schedule 9, Group 5 (Finance VAT Exemptions) Item number 1. The issue, transfer or receipt of, or any dealing with, money, any security for money or any note or order for the payment of money. 2. The making of any advance or the granting of any credit. 2A. The management of credit by the person granting it. 3. The provision of the facility of instalment credit finance in a hire-purchase, conditional sale or credit sale agreement for which facility a separate charge is made and disclosed to the recipient of the supply of goods. 4. The provision of administrative arrangements and documentation and the transfer of title to the goods in connection with the supply described in item 3 if the total consideration thereof [sic] is specified in the agreement and does not exceed £10. 5. The provision of intermediary services in relation to any transaction comprised in item 1, 2, 3, 4 or 6 (whether or not any such transaction is finally concluded) by a person acting in an intermediary capacity. 5A. The underwriting of an issue within item 1 or any transaction within item 6. 6. The issue, transfer or receipt of, or any dealing with, any security or secondary security being - (a) shares, stocks, bonds, notes (other than promissory notes), debentures, debenture stock or shares in an oil royalty, or (b) any document relating to money, in any currency, which has been deposited with the issuer or some other person, being a document which recognises an obligation to pay a stated amount to bearer or to order, with or without interest, and being a document by the delivery of which, with or without endorsement, the right to receive that stated amount, with or without interest, is transferable, or (c) any bill, note or other obligation of the Treasury or of a Government in any part of the world, being a document by the delivery of which, with or without endorsement, title is transferable, and not being an obligation which is or has been legal tender in any part of the world, or (d) any letter of allotment or rights, any warrant conferring an option to acquire a security included in this item, any renounceable or scrip certificates, rights coupons, coupons representing dividends or interest on such a security, bond mandates or other documents conferring or containing evidence of title to or rights in respect of such a security, or (e) units or other documents conferring rights under any trust established for the purpose, or having the effect of providing, for persons having funds available for investment, facilities for the participation by them as beneficiaries under the trust, in any profits or income arising from the acquisition, holding, management or disposal of any property whatsoever. 7. [Omitted by SI 1999/594, article 4] 8. The operation of any current, deposit or savings account. 9. The management of an authorised unit trust scheme or of a trust based scheme. 10. The management of the scheme property of an open-ended investment company. Banking and VAT-Guide on How VAT Applies in Banking

Ireland VAT Guide, including how VAT works in Ireland including the rules around VAT Registrtaion, VAT recovery, importing and exporting and much more. Introduction Value-Added Tax (VAT) is a tax, which is payable on sales of goods or services within the territory of the Member States of the EU. The tax, in all cases, is ultimately payable by the final consumer of the good or service. Each party in the chain of supply (manufacturer, wholesaler and retailer) acts as a VAT collector. They collect VAT from their customer and include that VAT in their VAT return to Revenue. When returning the VAT collected, they can reclaim as appropriate, VAT which has been charged to them by their suppliers. Current VAT Rates in Ireland (Effective 1 January 2023) Standard rate (23 %) Reduced rate (13.5 %) Second reduced rate (9 %) Livestock rate (4.8 %) Flat-rate compensation percentage for Farmers (5 %) Accountable Person An accountable person is a taxable person (for example, an individual, partnership, company) who: supplies taxable goods or services in the State and is registered or required to register for VAT. As such they are required to charge VAT in the State. Taxable Person A taxable person is any person who independently carries out a business in the European Union (EU) or elsewhere. It includes persons who are exempt from Value-Added Tax (VAT) as well as flat-rate (unregistered) farmers. Exemption From VAT Where a taxable person supplies only exempt goods or services, they are not generally entitled to register for Value-Added Tax (VAT). However, in specific circumstances the trader may be required to register and account for VAT. This occurs where the trader makes intra-Community acquisitions , or is in receipt of services from abroad. Likewise, a taxable person who also supplies taxable goods or services may be required to register for VAT. However, VAT registration relates to your taxable supplies. Therefore, if you carry out both exempt and taxable activities, you can only reclaim VAT relating to your taxable activities. VAT Registration Generally, you must register for VAT if you are an accountable person . A person carrying out only exempt activities or non taxable activities may not register for VAT. However, a person carrying on exempt activities or non taxable activities may have to register for VAT in certain situations, for example: acquiring goods from other Member States or receiving services from abroad . If you have set up a business but have yet to supply taxable goods or services, you may reclaim VAT on your start-up costs. However, to do so you are required to register for VAT. This will enable you to obtain credit for VAT on purchases made before trading begins. Traders whose turnover is below the VAT thresholds, farmers and sea fishers are not generally obliged to register for VAT. They may, however, elect to register for VAT. VAT Registration Thresholds Value-Added Tax (VAT) registration is obligatory when your turnover exceeds, or is likely to exceed, the VAT thresholds. The thresholds depend on your turnover in any continuous 12 month period. The threshold for intra-Community distance sales of goods and cross-border telecommunications, broadcasting and electronic (TBE) services relies on your turnover in a calendar year. If the turnover is less than a threshold limit, you may elect to register for VAT. The principal thresholds are as follows: €37,500 in the case of persons supplying services only. €10,000 for taxable persons making mail-order or intra-Community distance sales of goods and cross-border TBE services into the State. The threshold is calculated by taking account of the suppliers, or deemed suppliers , total value of intra-Community distance sales of goods and cross-border TBE services to customers in all European Union (EU) Member States. The threshold only applies where the supplier is established and has their permanent address, or usually resides, in only one Member State. Otherwise the supplier must register for Irish VAT in respect of such supplies. See the intra-Community distance sales of goods and the Electronically supplied services webpages for further information. €41,000 for persons making acquisitions from other EU Member States. €75,000 for persons supplying goods. €75,000 for persons supplying both goods and services where 90% or more of the turnover is from the supplies of goods. However, while all goods and services are part of the turnover, the 90% does not necessarily include all goods sold. The 90% figure does not include goods which you: sold at the standard or reduced rates and manufactured or produced from zero rated materials. A person, while not established in the State, needs to register and account for VAT if that person supplies: taxable goods to ‘taxable customers’ in the State or services to ‘taxable customers’ in the State. This applies irrespective of the level of turnover. How is Turnover Determined Your turnover figure may exceed the threshold limit. However, you may not be required to register for VAT. For registration purposes, the turnover figure may be reduced by the amount of VAT paid on stock bought for re-sale. You should use this reduced turnover figure to see if you can register for VAT. This adjusted turnover figure is used only for the purposes of determining your turnover for registration for VAT. Example Michael has an annual turnover of €80,000. He has incurred VAT on his stock purchased for re-sale in the amount of €11,220. Michael can reduce his turnover figure by the €11,220 when determining whether he has breached the threshold. €80,000 minus €11,220 equals €68,780. As the adjusted turnover is below the registration limit of €75,000, he is not obliged to register. Requirement to Register where Goods or Servic es Purchased from Abroad Usually the following persons would not need to register for Value-Added Tax (VAT) in the state: Non VAT registered businesses Exempt businesses such as banks Public bodies such as local authorities, State agencies and semi-State bodies Farmers, fishers or race horse trainers. But they may have to register and account for VAT, for received taxable services from outside the State or Intra-Community Acquisitions. Exempt and Certain Non Taxable Persons Acquiring Goods Within the EU Exempt persons and certain non-taxable persons are obliged to register and account for VAT in certain situations. Such situations include where they buy or are likely to buy, goods from other Member States. You need to register when the goods exceeds, or are likely to exceed €41,000 in any 12 month period. Flat-rate farmers, fishers and race-horse trainers may be required to register in respect of receiving such goods, subject to the relevant threshold. They can retain their unregistered status in respect of their farming or fishing activities. You may not reclaim VAT if you are an exempt or non-taxable person. Exempt and Certain Non Taxable Persons Receiving Services From Abroad (Reverse Charges) Exempt persons and certain non-taxable persons must register and account for VAT if they receive taxable services from abroad. This obligation arises irrespective of the value of those services. Flat-rate farmers, fishers and race-horse trainers need to register if they receive such services. They can retain their unregistered status in respect of their farming or fishing activities. You may not reclaim VAT if you are an exempt or non-taxable person. Paying VAT on Services Received from Abroad (Reverse Charges) You must pay VAT on the invoiced amounts at the appropriate Irish VAT rate to Revenue in your periodic VAT return. You may qualify to reclaim the VAT at the same time. By passing your VAT number to the supplier, you will avoid paying VAT in the other Member State. For M ore Information on Registering f or VAT Click this Link Registering for VAT Modernisation of VAT & Implementation of e - Invoicing The Irish Revenue has published a report on the Modernisation of VAT and the Implementation of e - invoicing in Ireland including the adoption of VIDA and a phased approach for e - invoicing from 1 November 2028. Please see the report link below. VAT Modernisation - Implementation of eInvoicing in Ireland Other Key Areas of VAT Charging VAT VAT Invoices Financial Services Agriculture Import & Export e commerce Accounting for VAT Property VAT on Services VAT on Goods VAT Recovery Non Established Credit Notes Self Billing VAT Records Construction Rev Chgs CG Scheme Retail Export Ireland-VAT Guide - Key Aspects of Irish VAT

Use our VAT Advisor powered by artificial intellegence to obtain detailed answers and summaries to questions you may have regarding UK & Global VAT compliance issues. VAT Digital AI - Intelligent VAT Advisor Online 24/7 ® At VATDIGITAL.COM - we aim to provide you with the latest VAT News, Compliance Guides, VAT Rules and information on topics such as VAT Accounting, VAT Risks and Controls, UK HMRC and Global Tax Authority updates, VAT Technology Tools and much more. To assist you in getting the most benefit from our website, we now have a VAT Advisor driven by artificial intelligence which will provide you with detailed guidance on a range of questions you may have in relation to VAT. Our online VAT Advisor will be able to assist on a range of topics including VAT Registration, VAT Invoicing, VAT Recovery, VAT Accounting, VAT and the P&L / Balance Sheet, Importing and Exporting, Recovery of VAT on Bad Debts, VAT Compliance Automation, VAT Risks, Mergers & Acquisitions VAT Due Dilligence, VAT and Online Market Places & Trading, VAT and Financial Services including Banking, Insurance, Commodities Trading, VAT and the Construction Industry and much more. Artificial Intelligence is fast becoming an integral part of the global tax function as companies continue their digital journey. Companies that don't embrace this technology will simply be left behind as it will be used to streamline Finance, Supply Chains, VAT & Tax Compliance / VAT Advisory and will deliver huge efficiencies and cost savings. The evolution of AI continues with Agentic AI, which moves away from prompt based generative AI to an AI agents based model. A collection of AI agents can plan and carry out tasks autonomously to achieve a desired objective such as preparing reports, Budgets, Financial Accounts, VAT and Tax Returns, VAT & Tax Reconciliations, VAT and Tax Analytical Reviews etc. AI and AI agents will completely revolutionise the Accounting and Tax landscape in the coming years - watch this space! VAT AI Advisor <

FTT - Barclays Services Corp vs HMRC - Fixed Establishment & HMRC Protection of Revenue Barclays Services Corp vs HMRC (Fixed Establishment) UTT Decision 8 June 2026 - UTT upholds HMRC's refusal to admit Barclays Services Corporation to the BBPLC VAT Group. (Upper Tribunal Tax and Chancery Decision of MR JUSTICE RAJAH and JUDGE THOMAS SCOTT on 08 June 2026) Dismissed on the grounds that it did not meet the necessary eligibility requirements for VAT grouping at the date of the application in terms of having sufficient human and technical resources in the UK to have a Fixed Establishment. UTT - disagreed with FTT conclusion on Protection of Revenue and would have concluded the opposite Link to UTT ruling below: ( 1) BARCLAYS SERVICES CORPORATION (2) ... In the FTT judgement, two key points were addressed: Whether BSC UK branch had a Fixed Establishment in the UK Whether HMRC had sufficient grounds for refusing the application for BSC UK Branch to join the VAT Group for the protection of the revenue. Barclays appeal against the rejection of its application for a UK branch of BSC US to join the VAT Group was dismissed on the grounds that it did not meet the necessary eligibility requirements for VAT grouping at the date of the application in terms of having sufficient human and technical resources in the UK to have a Fixed Establishment. The FTT however dismissed the second point on "protection of the revenue" on the basis that, had BSC UK had the necessary human and technical resources to be considered as having a fixed establishment in the UK as at the date of the application to join the VAT group, the VAT savings on its admission would be those that fell within the normal consequences of VAT grouping. See link to full FTT judgement below: Barclays Service Corporation & Anor v The Commissioners for HMRC - Find case law - The National Archives

UK Tax Rates: Corporation Tax, Income Tax, Inheritance Tax and VAT UK - TAX Rates Corporation Tax Rates Rate 2024/25 Main Rate 25% Small Profit Rate 19% Marginal Rate 26.50% Capital Gains Tax Rates Asset 2024/25 Residential Property 25% Other Assets 19% Investment Trust 28% (Carried Interest) * Tax Free Allowance £3,000, £1,500 Unit Trusts VAT Rates Rate 2024/25 Standard Rate 20% Reduced Rate 5% Zero Rate 0% Income Tax Rates Band Taxable Income Tax Rate Personal Allowance upto £12,570 0% Basic Rate £12,570 - £50,270 20% Higher Rate £50,271 - £125,140 40% Additional Rate £125,140 and above 45% Inheritance Tax Rates Band Taxable Income Tax Rate Tax Free Threshold £325,000 0% Taxed Above £325,000 40% Personal Savings Allowance Income Tax Band Personal Savings Allowance Basic Rate £1,000 Higher Rate £500 Additional Rate £0 Tax on Dividends Income Tax Band Tax Rate Over the Allowance Basic Rate 8.75% Higher Rate 33.75% Additional Rate 39.35% * Dividend Allowance TY 2024 /2025 = £500 Stamp Duty Land Tax (SDLT) Property Value SDLT Rate 0 to £125,000 0% £125,001 to £250,000 2% £250,001 to £925,000 5% £925,001 to £1,500,000 10% £1,500,001 and above 12%

Find out how VAT works in Austria VAT including VAT rules, VAT registration, imports and exports and much more. VAT - Ghana VAT - Ghana Austria-VAT Introduction There are three main rates of VAT in Austria, Standard Rate 20% , Reduced Rate 13% and Reduced Rate 10%. VAT Rates VAT Exemptions VAT Return Taxable Supplies Invoicing Reverse Charges Input VAT Deduct

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Comprehnsive guide for the different VAT rates applicable to various goods and services in the UK, including Health, Transport, Land & Buildings, Education, Charities etc. VAT Rates For Goods & Services Food and Drink Food and drink for human consumption is usually zero-rated but some items are always standard-rated. These include: catering alcoholic drinks confectionery crisps and savoury snacks hot food sports drinks hot takeaways ice cream soft drinks and mineral water Restaurants must always charge VAT on everything eaten either on their premises or in communal areas designated for their customers to use, such as shared tables in a shopping centre or airport food courts. In addition, restaurants and takeaway vendors must charge VAT on all hot takeaways and home deliveries, but do not need to charge VAT on cold takeaway food unless it’s to be eaten in a designated area. Animals and animal food Supplies of live animals that are zero-rated You can zero rate the sale, hire or loan or supply of a part interest (a share) of a live animal provided it’s of a kind generally used in the UK, or yielding or producing food for human consumption. Animal includes bird, fish, crustacean and mollusc. Examples of Zero Rated Animals are: meat animals dairy animals poultry (except ornamental breeds), including those for egg production, honey bees fish (except ornamental breeds and coarse fish), including those for production of edible roes Animals that are standard-rated Examples of standard-rated animals are: bumble bees ornamental birds and fish racing pigeons horses Live kangaroos Pets Animals that will be kept as pets can be zero-rated only if they are of a kind that is normally used for human food production. For example, rabbits, other than ornamental breeds, are always zero-rated. Animals kept for non-food purposes Animals kept for non-food purposes can be zero-rated if they are of a kind normally producing food for human consumption. Sheep kept mainly for their wool, or bulls used for breeding are zero-rated. Birds Most breeds of chicken are zero-rated, as are game birds and ostriches. Ornamental breeds of birds are standard-rated. The following breeds of ducks, geese and turkeys are zero-rated: Type of fowl Breed Ducks - Aylesbury, Campbell (Khaki Campbell), Indian Runner, Muscovy, Pekin and derivatives and crossbreeds of these Geese - Brecon Buff, Chinese Commercial, Embdem, Roman, Toulouse and derivatives and crossbreeds of these Turkeys - Beltsville White, British White, Broadbreasted White, Bronze (Broadbreasted Bronze), Norfolk Black and derivatives and crossbreeds of these Fish Freshwater fish - Eels, salmon and trout and others recognised as food for human consumption are zero rated. Bream, perch, pike, carp and tench are standard rated. Shellfish - Oysters, mussels, whelks are zero rated while non food species are standard rated Fish for aquaria -All supplies are standard rated Fish used as bait - Fish of a kind, and fit for, human consumption are zero rated and all other supplies are standard rated. Ornamental fish - for example koi carp Agricultural and horticultural crops Crops covered by the relief All crops that are specifically grown to produce food of a kind for human consumption or animal feeding stuffs are zero-rated. The zero rate also applies to seeds, seedlings, crowns, spores, tubers and bulbs of edible vegetables and fruit. What’s not covered by the relief Any crop that generally produces items that are not fed to humans or animals is always standard-rated. Plants that are primarily grown for their ornamental effect (such as ornamental nursery stock including trees, shrubs, herbaceous plants, alpines and pot plants) are standard-rated. Plants, seeds and fruit of a kind used for the production of perfumes, pharmaceutical products, insecticides, fungicides and other non-food uses are standard-rated. Some examples of plants that are standard-rated are: Evening primrose, because this is grown for the extraction of its oil Tulips and Hyacinths, because these are grown and sold for ornamental purposes Norfolk reed, because this is grown for thatching material Sport, leisure, culture and antiques Betting and gaming — including pool betting and games of chance is Exempt from VAT Bingo — including remote games played on the internet, telephone, television or radio is Exempt from VAT Bingo — including remote games played on the internet, telephone, television or radio is Exempt from VAT Lottery ticket sales is Exempt from VAT Online lottery games is exempt from VAT Retailer commission on lottery ticket sales is Exempt from VAT Culture Admission charges by public authorities or eligible cultural bodies to certain cultural events such as visits to museums, art exhibitions, zoos and performances is Exempt from VAT Antiques Antiques, works of art or similar (as assets of historic houses) sold by private treaty to public collections are exempt from VAT Antiques, works of art or similar (as assets of historic houses) used to settle a tax or estate duty debt with HMRC again are exempt from VAT Health, education, welfare and charities Charities Admission charges by charities are Exempt from VAT Advertising services for charities VAT are zero rated Certain goods sold at charitable fundraising events are zero rated Charitable fundraising events are Exempt from VAT Charity shops — selling donated goods is zero rated for VAT Construction and sale of new buildings for a relevant charitable purpose are zero rated for VAT Energy-saving materials permanently installed in dwellings and buildings used for a relevant residential purpose providing the total cost of them (not including VAT) is not over 60% of the cost of the installation of the products (not including VAT) 5% reduced rate VAT applies. Energy-saving materials — supply only — are Standard-Rated (20%) Sponsored charitable events are Exempt from VAT. Voluntary donations to charities are outside the scope of VAT Welfare Building services for disabled people are zero rated for VAT Burial or cremation of dead people, or burial at sea is Exempt from VAT Mobility aids for the elderly, 5% reduced rate VAT applies Equipment for blind or partially sighted people is zero rated Equipment for disabled people is zero rated for VAT Funeral plans written under contracts of insurance are Exempt from VAT Smoking cessation products — nicotine patches and gum, 5% reduced rate VAT applies Welfare services provided by charities at significantly below cost are Outside the scope of VAT Magnetic tape adapted for recording speech for blind people together with apparatus for making and playing the adapted tape and certain low vision aids are zero rated. Health Care or medical treatment provided by a qualifying institution like a hospital, hospice or nursing home are Exempt Dispensing of prescriptions by a registered pharmacist is zero rated for VAT Health services provided by registered doctors, dentists, opticians, pharmacists and other health professionals is Exempt from VAT Incontinence products are zero rated. Maternity pads are zero rated Sanitary protection products are zero rated Low vision aids are zero rated Education Education and vocational training provided by an eligible body other than a ‘private school’. Goods or services closely connected to the education provided by an eligible body like a school, college or university is Exempt from VAT. VAT Notice 701/30 Building and construction Substantial reconstructions to protected buildings that are buildings used as a dwelling, for a relevant residential purpose or for a relevant charitable purpose is zero rated VAT Notice 708 The installation of a bathroom or lavatory, constructing ramps and widening doorways or passageways for disabled people in their own home is zero rated Building services for disabled people Construction and first freehold or long leasehold sale of a new building for a relevant charitable purpose is zero rated. VAT Notice 708 Construction and first freehold or long leasehold sale of a new building for relevant residential purposes is zero rated. VAT Notice 708 Construction and first freehold or long leasehold sale of new domestic buildings is zero rated. VAT Notice 708 Converting existing premises by increasing the number of dwellings within the building, 5% VAT applies. VAT Notice 708 Renovating a dwelling that has been empty for at least 2 years 5% VAT applies. VAT Notice 708 First freehold or long leasehold sale of a commercial building converted into a dwelling or dwellings is zero rated. VAT Notice 708 First freehold or long leasehold sale of buildings converted for relevant residential purposes is zero rated. VAT Notice 708 First freehold or long leasehold sale of buildings converted for relevant charitable purposes is zero rated. VAT Notice 708 Land and property Garages or parking spaces let together with dwellings (under short hold tenancy agreements) for permanent residential use are Exempt from VAT. — VAT Notice 742 Parking — grant, or licence, to occupy land on which incidental parking takes place is Exempt from VAT. VAT Notice 742 Property, land and buildings — grant, or licence, to occupy land or buildings is Exempt from VAT. VAT Notice 742 Sale or long lease of a new dwelling with garage or parking space is zero rated for VAT. VAT Notice 708 Transport, freight, travel and vehicles Transport Aircraft repair and maintenance is zero rated for VAT. VAT Notice 744C Travel Houseboat moorings are Exempt from VAT. VAT Notice 742 Parking spaces or garages supplied with houseboat moorings are Exempt from VAT. VAT Notice 742 Passenger transport in a vehicle, boat or aircraft that carries not less than 10 passengers is zero rated for VAT. VAT Notice 744A Tolls for bridges, tunnels and roads operated by public authorities is Outside the scope of VAT. Privately-operated tolls for bridges, tunnels and roads are standard-rated — VAT Notice 700 Freight Freight transport to or from a place outside the UK is zero rated for VAT. Domestic freight transport is standard-rated, unless it is the domestic leg of freight transport between the UK and another country in which it is zero rated. — VAT Notice 744B Freight containers — sale, lease or hire to a place outside the UK and the EU is zero rated. VAT Notice 703/1 International freight transport that takes place in the UK and its territorial waters is zero rated. VAT Notice 744B Vehicles Aircraft repair and maintenance is zero rated. VAT Notice 744C Airships — sale or charter is zero rated. VAT Notice 744C Caravans (more than 7 metres long or more than 2.55 metres wide) is zero rated or 5%. Taxing holiday caravans Civil aeroplanes — sale or charter is zero rated for VAT. Gliders — sale or charter — are standard-rated as are hot air balloons — VAT Notice 744C Helicopters — sale or charter is zero rated for VAT. VAT Notice 744C Houseboats — sale or let out on hire is zero rated for VAT, But holiday accommodation let in a moored houseboat is standard-rated — VAT Notice 701/20 Military aeroplanes — sale or charter is zero rated for VAT. VAT Notice 744C Ship repairs and maintenance is zero rated for VAT. VAT Notice 744C Shipbuilding — 15 tons or over gross tonnage is zero rated for VAT. VAT Notice 744C Printing, postage, publications — books, magazines and newspapers Printing Brochures is zero rated for VAT. VAT Notice 701/10 Leaflets is zero rated for VAT. VAT Notice 701/10 Pamphlets is zero rated for VAT. VAT Notice 701/10 Postage Direct-mail postal services meeting all the conditions of VAT Notice 700/24 3.2 and 3.3 are Outside the scope of VAT. VAT Notice 700/24 Postage, packing and delivery within the UK included in the sales contract but charged for separately, for example, mail order The same rate as the goods being delivered or posted Postage, packing and delivery within the UK charged as an optional extra is always standard-rated — VAT Notice 700/24 Public postal services provided by the Royal Mail under a universal service obligation are Exempt from VAT. Standard Royal Mail first and second class services for example Other postal services that are not subject to a universal service obligation are Standard-Rated (20%) Supplies that are not subject to regulation Publications Books are zero rated for VAT. VAT Notice 701/10 Children’s painting and picture books are zero rated for VAT. VAT Notice 701/10 Maps and charts are zero rated for VAT. VAT Notice 701/10 Magazines are zero rated for VAT. VAT Notice 701/10 Newspapers are zero rated for VAT. VAT Notice 701/10 Printed or copied music are zero rated for VAT. VAT Notice 701/10 Publications are zero rated for VAT. Some items are standard-rated such as exercise books, letterheads, posters — VAT Notice 701/10 Clothing and footwear, protective and safety equipment Clothing and footwear Babywear is zero rated for VAT. VAT Notice 714 Children’s clothes and footwear is zero rated for VAT. VAT Notice 714 Protective and safety equipment Carrycots with restraint straps, 5% VAT applies. VAT Notice 701/23 Children’s car seats, booster seats and booster cushions , 5% VAT applies. VAT Notice 701/23 Children’s safety seats with bare wheeled framework, 5% VAT applies. Prams and pushchairs are standard-rated (20%) — VAT Notice 701/23 Cycle helmets — CE marked are zero rated for VAT. VAT Notice 701/23 Motorcycle helmets that meet safety standards are zero rated for VAT. VAT Notice 701/23 Protective boots and helmets for industrial use are zero rated for VAT. VAT Notice 701/23 Open Government Licence v3.0

The page provides details of the VAT liability of the sale of Debt, Asset Purchases, Factoring, Asset Based Lending etc. Sale of Debt The sale of a debt is a financial transaction, whereby the purchaser acquires ownership of debts from a creditor, at a nominal sum to the face value of the debts. The purchaser assumes all the rights and obligations of the original creditor and all legal and beneficial or equitable interest passes to the buyer to whom full title and risk is transferred. The purchaser of a debt portfolio may either use an in-house operation to effect recovery or contract with one or more debt recovery agencies for use of their collections services as described in VATFIN3255. Depending on the contractual agreement with the original creditor, the purchaser may sell on all or part of the debts acquired. The purchaser of a debt portfolio has no right of recourse to the seller for un recovered debts except where debts are deemed to be irrecoverable prior to the date of purchase e.g. deceased customers. In some cases the sale contract may allow the purchaser to return these accounts and gain a return of the relevant purchase amount. Unless there is a charge-back agreement for unsupported balances, the purchaser does not return uncollected debts to the original creditor - the purchaser will write off the debts and take the loss. Debt purchase companies may also offer contingency debt collection services as described in VATFIN3255. In the sale of a debt, all legal and beneficial or equitable interest passes to the buyer to whom full title and risk is transferred. Assignment of a debt for purposes of this guidance we distinguish the assignment of a debt from a sale of a debt, in that with an assignment only the equitable interest is passed to the assignee and the assignor retains the legal interest in the debt and any liability to obligations arising from the original contract. Often it will not be possible for the assignee to sell that which has been assigned. The use of the term ‘assignment’ can cause misunderstanding and it is essential to be quite clear as to what is actually happening in any particular set of circumstances. If doubts arise, the VAT Deductions & Financial Services Team should be consulted. Supply and liabilitySale of a debt The sale of a debt is Exempt from VAT under the VAT Act 1994, Schedule 9, Group 5, item 1. Note where the actual customers are purchased by a business also, there will be two distinct transactions namely the purchase of the assets and the purchase of the debt. Input tax incurred by a business chasing debts it has bought relates to a business activity. The input tax incurred by a business for use in making a supply in the course of business may be recoverable subject to the normal rules. For further information on business/non-business see V1-6 - Business/non-business. As the sale of debt is Exempt as mentioned above, the income from the sale will have an impact on an organisation's partial exemption recovery rate. Factoring / Invoice Discounting The term ‘factoring’ covers a variety of services involving debt assignment (often referred to as the purchase of debts), which the factor may provide to clients in respect of debts owing from their trade debtors. The advantages to the client may include some or all of the following: immediate finance (the up-front payment of, typically, 80% of the debt) protection against bad debts sales ledger administration a debt collection service, from initial contact with the debtors through to legal enforcement provision of credit information on customers provision of legal advice and provision of management information. Factoring Products A variety of terms are in use but the products the factor offers his client may include the following: Full Service (also known as non-recourse, old line, main line or traditional factoring): the factor is assigned the debt (which is disclosed to the debtor), opens a line of credit to the client, provides a full sales ledger service, sends debtors notices of assignments, undertakes recovery action and bears the loss if the debtor defaults in certain circumstances. Recourse factoring: as for the Full Service except that the factor does not bear the loss if the debtor defaults but has the right to assign the debt back to the client. Maturity factoring: the non-recourse service but without the provision of the line of credit for an immediate payment on account. Payment in full of the purchase price is made either upon receipt from the debtor or at the end of a fixed ‘maturity period’. This is usually based upon prior overall collection period of the entire ledger. Agency factoring (sometimes known as bulk factoring or agency discounting): the factoring arrangement is disclosed to the client’s debtors; the factor extends the line of credit but does not bear any loss. The client operates his own sales ledger and debt recovery system as the agent of the factor. Invoice discounting (also known as confidential factoring or undisclosed factoring): as for agency factoring but the factoring arrangement is not disclosed to the debtor. Can be with or without recourse. Undisclosed factoring: an invoice discounting arrangement with a limited debt protection facility - the factor agrees to bear a proportion of unrecoverable debts. You may also find further variants of the above. The Factoring Process The factor typically takes an equitable assignment of his client’s debts. This gives him certain legal rights without full legal ownership of the debt; it enables him to pursue the debt and, in the event of the client’s insolvency, gives him preferential rights over the income from the debt. Historically the factor did not take a legal assignment of the debt since this incurred stamp duty. This is likely to continue even though stamp duty has been abolished on the assignment of debts. Under his agreement with the client the factor may act on a recourse or non-recourse basis. In a recourse agreement he will, if the money cannot be recovered from the debtor, reassign the debt back to the client. In a non- recourse agreement the factor will bear the loss in the absence of any breach of the agreement between the factor and his client. The factor opens a client account ( sometimes called a ‘current account’) to which he credits the face value of the debts he has bought and debits his charges (these may be consideration for a number of standard rated supplies of administrative, clerical and accounting services). The balance, less an agreed retention, is available for the client to draw upon. The factor debits to the account any payments to the client and also a finance charge, sometimes described as a ‘discount’, ‘discount charge’ or ‘discounting charge’. Liability - EC law Article 135.1 (d) of the VAT directive specifically excludes debt collection and factoring from exemption: Transactions, including negotiation, concerning … but excluding debt collection and factoring Prior to this, Article 13B(d)(3) of the Sixth VAT Directive specifically excluded both debt collection and factoring from the exemption. When the Directive was recast into its current form however it was agreed that, as factoring was in any event a form of debt collection, it was not necessary to include the words ‘and factoring’ in the new version. Services of factoring and debt collection are therefore liable to VAT at the standard rate. The decision of the ECJ in the appeal of MKG-Kraftfahrzeuge-Factory GmbH (‘MKG’ - C-305/01 ([2003] STC 951) confirmed that the supply of factoring is essentially taxable. In GKFL Financial Services AG (“GKFL”- C-93/10) the ECJ held that an operator who purchases defaulted loan receivables at its own risk and at a price below their face value does not make a supply of services for a consideration for VAT purposes. The ECJ considered whether, as a purchaser of debts, GKFL was providing some form of debt collection service back to the bank that sold the debt (i.e. following the ECJ judgement in MKG – see above) for which the consideration would have being the deduction made from the face value of the debt in calculating the purchase price. The ECJ concluded that GKFL did not receive any consideration from the bank, as the difference between the purchase price of the debts and their face value was merely a reflection of the actual economic face value of the debts at the time of purchase. By contrast, in the case of MKG, the assignee of the debts did make a supply of services to the assignor because it received consideration for those services by way of a factoring commission and a del crede fee. Discount charges Where a factor provides credit in that the client can, as explained above, draw upon the account for which it is charged interest it will take the form of a ‘discount’, ‘discount charge’ or ‘discounting charge’. VAT Treatment is Exempt Administration or Service Charge (This may cover the provision of a full sales ledger management service, credit advice, debt collection service and the provision of management information). VAT Treatment is Standard Rated. . Guarantee of payment. VAT Treatment is Standard Rated. Assignment or re-assignment of debt. Outside The Scope of VAT Electronic transfer of funds (if charged for separately). VAT Treatment is Exempt For the VAT treatment of the ‘discount’ and other factoring related services please see paragraph 5.5 in VAT Notice 701/49 Finance Place of supply A UK factor may rely upon an overseas associate to collect a debt or may provide such services himself within the UK for an overseas factor. To determine the place of supply please see VATPOSS . Partial exemption, bad debt relief and cash accounting The factor will make both taxable and exempt supplies and will therefore be partly exempt. Where he provides significant administrative or accounting services to the client his standard rated supplies will allow him a high input tax recovery. Where, as in invoice discounting, the credit facility is the predominant feature of the agreement his input tax recovery will be lower. Factoring and bad debt relief A factor cannot claim bad debt relief for debts assigned to him by his client. The client cannot claim bad debt relief for a debt assigned to a factor but can do so if the factor re-assigns the debt to him (see VAT Notice 700/18: relief from VAT on bad debts ). Factoring and cash accounting Please see Notice 731 Cash Accounting for details on how to treat the debt for cash accounting purposes. Asset Based Lending Asset based lending is usually operated in conjunction with one of the factoring products (see VATFIN3220 ), except that the amount that the client can draw down can also take into account a percentage of the value of the client’s stock and inventory. Thus funds will be provided against invoices, stock, plant and machinery, land and buildings. Between 65% and 85% will be loaned, depending on the type of item. Lenders in an asset based lending situation have a charge over the above assets that can be invoked in the instance of default. The supply of credit is exempt under the VAT Act 1994, Schedule 9, Group 5, item 2. Sale of Debt and VAT

VAT Guide for Argentina. Including VAT Rates, Goods and Services subject to VAT including imports and Exports etc. Argentina-VAT Proposed VAT Reform - May 2025 The Government of Argentina is aiming to simplify the tax system by placing more power for levying taxes within the provinces. This includes a proposed "Super VAT" whereby the current VAT rate would be split between the federal Government (9%) and the provinces would be allowed to set their own rates between the 9% federal Gov't rate up to the 21% rate. Current VAT The current general rate of VAT in Argentina is 21% and is applied on the sales value of products and services (including professional services), with a few specific exceptions. This tax is applicable to imports of goods and services (services rendered abroad and used or exploited in Argentina). The tax paid on imports can be taken as VAT credit. Certain goods are taxed at a reduced rate of 10.5%, for example, works on real estate for housing, services related to agriculture, operations of certain capital goods and food. Beside, some services taxed at 27%, for example, gas, energy and telephone services. Reverse Charge VAT As a result of the 2017 tax reform, VAT legislation currently includes ‘digital transactions' (e.g. digital services, hosting, on-line technical support, software services, Internet services) provided from abroad as a taxable event. Hence, these types of services are now subject to VAT at a 21% rate if they are provided by a non-resident entity to an Argentine final customer, on condition that they are actually used in Argentina. Exports of goods and services (services rendered in Argentina and used or exploited abroad) are taxed at 0%, which implies that input VAT (VAT credit on purchases of goods and services) related to exports may either be used as a credit against output VAT or refunded pursuant to a special procedure. VAT paid on purchases, final imports and rental of automobiles, not considered as inventory, may not be computed by the purchaser as a credit. The same tax treatment applies to other services, such as those provided by restaurants, hotels and garages. The above-mentioned restrictions do not apply when the engagement of these services is for a conference, congress, convention or any other similar event directly related to the specific activity of the contracting party. Source - Argentine Tax Authority