What is the place of supply for VAT purposes?
Answered 11 March 2026
Here is a comprehensive answer on the place of supply for VAT purposes:
What the Law Says
The Charging Provision
UK VAT is only charged on supplies made in the United Kingdom. Section 4(1) of the VAT Act 1994 provides that VAT shall be charged on any supply of goods or services made in the UK, where it is a taxable supply made by a taxable person in the course or furtherance of any business. The place of supply rules address whether that condition is met.
The governing legislation is found in sections 7 to 9A of the VAT Act 1994.
Place of Supply: Goods
The rules under s.7 VATA 1994 operate as follows:
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No removal involved (s.7(2)): If the supply does not involve removal of goods to or from the UK, the goods are treated as supplied in the UK if they are in the UK at the time of supply, and outside the UK otherwise.
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Installation or assembly (s.7(3)): Goods are treated as supplied in the UK where their supply involves installation or assembly at a place in the UK to which they are removed; and outside the UK where installation or assembly takes place outside the UK.
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Goods involving removal to/from the UK (s.7(7)): Where s.7(2) does not apply because the supply involves removal to or from the UK, the supply is treated as made in the UK where it involves removal from the UK, and outside the UK in any other case.
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Imported goods (s.7(6)): Where goods are imported into the UK and the supplier is the importer, the supply is treated as taking place in the UK. If the customer imports the goods, the supply is treated as taking place outside the UK.
Place of Supply: Services
There are two general rules depending on whether the supply is business-to-business (B2B) or business-to-consumer (B2C):
- B2B general rule: The place of supply is where the customer belongs.
- B2C general rule: The place of supply is where the supplier belongs.
There are also special rules for certain categories of services (e.g. land-related services, transport, telecommunications, electronically supplied services) which override the general rules.
HMRC Guidance / Practice
Core Principle
The place of supply is the place where a supply is treated as being supplied — this is the place where it is liable to VAT (if any). If the supply is in the UK, it is subject to UK VAT. If it is in another country, it is "outside the scope" of UK VAT.
The place of supply rules exist to ensure VAT is paid only in the correct country and to avoid supplies being taxed more than once or not at all.
Goods — Basic Principle
Goods are normally treated as being supplied where they are located at the time of supply, not where the supplier is located. For example, a UK business sourcing goods from outside the UK and delivering them directly to an overseas customer makes a supply outside the UK, regardless of invoicing from the UK.
Services — Practical Examples
- A UK supplier providing administrative services to a French VAT-registered customer: B2B supply → place of supply is France → outside the scope of UK VAT.
- A UK consultant providing advisory services to an Italian organisation that cannot evidence business status: treated as B2C → place of supply is where the supplier (UK) belongs → UK VAT applies.
- A Danish company providing advertising to a UK VAT-registered charity: B2B → place of supply is where the customer (UK) belongs → the charity accounts for VAT via the reverse charge.
Use and Enjoyment Rules
For certain services (e.g. telecommunications, electronically supplied services, hiring of goods, broadcasting), use and enjoyment rules apply. These shift the place of supply to where the services are actually consumed, overriding the normal supplier/customer location rules, to prevent distortive outcomes.
EU Law Reference (for services)
Article 44 of the EU VAT Directive 2006/112/EC defines the place of supply of services to a taxable person as: (1) where that person has established their business; (2) where services are provided to a fixed establishment elsewhere, the place of that fixed establishment; or (3) in the absence of either, the recipient's permanent address or usual residence.
Citation sources
Section 7 VAT Act 1994 7(7) Goods whose place of supply is not determined under any of the preceding provisions of this section but whose supply involves their removal to or from the United Kingdom shall be treated - (a) as supplied in the United Kingdom where their supply involves their removal from the United Kingdom without also involving their previous removal to the United Kingdom; and (b) as supplied outside the United Kingdom in any other case
The general rule for B2C supplies of services is that the place of supply is where the supplier belongs, irrespective of the location of their customer.
For VAT purposes, the place of supply of a service is the place where that service is treated as being supplied. This is the place where it’s liable to VAT (if any). If the supply is in the UK it is subject to UK VAT. If the supply is in an EU member state or another country it is said to be ‘outside the scope’ of UK VAT.
oint created by the removal. Pursuant to section 6(5) where an invoice is issued within 14 days of the basic tax point the time of supply can be deferred to the date of the invoice. (4) Section 7 VATA lays out the basis on which the place of supply is determined. 7(2) states that: “if the supply of any goods does not involve their removal from or to the United Kingdom they shall be treated as supplied in the United Kingdom if they are in the United Kingdom and otherwise shall be treated as suppl
The ‘use and enjoyment’ rules apply to the following supplies: B2B supplies of telecommunication services electronically supplied services insurance repair services B2B and B2C supplies of hiring of goods hiring of means of transport broadcasting services Effective use and enjoyment take place where a recipient actually consumes services irrespective of the contractual arrangements, payment or beneficial interest. These rules prevent distortive outcomes that would happen if we only considered th
A UK supplier provides administrative services to a customer in France. The customer provides a valid French registration number. The supply is therefore being made B2B and so the general rule says that the place of supply is where the recipient belongs. As this is France, the supply is outside of the scope of UK VAT. A consultant in the UK provides advisory services to an Italian trade organization, which is a limited company. The customer is unable to provide a VAT number or any other supporti
Place of supply The normal position is that a business without UK establishment is liable to register under Schedule 1A of the VAT Act 1994 if it makes taxable supplies of any value or intends to do so in the next 30 days. A taxable supply is a supply of goods or services made in the UK other than an exempt supply – section 4(2) of the VAT Act. A key consideration is whether a supply takes place in the UK. An overseas business may not need to register if all the supplies in the UK are: subject t
Section 7 VAT Act 1994 7(3) Goods shall be treated - (a) as supplied in the United Kingdom where their supply involves their installation or assembly at a place in the United Kingdom to which they are removed; and (b) as supplied outside the United Kingdom where their supply involves their installation or assembly at a place outside the United Kingdom to which they are removed.
The scope of VAT is defined in Section 4 of the VAT Act 1994 4(1) VAT shall be charged on any supply of goods or services made in the United Kingdom, where it is a taxable supply made by a taxable person in the course or furtherance of any business carried on by him (2) A taxable supply is a supply of goods or services made in the United Kingdom other than an exempt supply. For VAT purposes, the country where a supply is deemed to be made is called the ‘place of supply’ and is the place where it
There are 2 general rules for determining the place of supply of services, one for business to business (B2B) and one for business to consumer (B2C). The B2B general rule for supplies of services is that the supply is made where the customer belongs. The B2C general rule for supplies of services is that the supply is made where the supplier belongs. There are also special place of supply rules for certain services. For more information read Place of supply of services (VAT Notice 741A). If you b
Goods are normally treated as being supplied where they are located at the time of supply and not where the supplier is located. Goods located: outside the UK are not exports and the supply is outside the scope of UK VAT in Northern Ireland that are sent to an EU destination should follow the rules for VAT on movements of goods between Northern Ireland and the EU in Great Britain that are sent to an EU destination should follow the export rules in this notice
The scope of UK VAT is defined in Section 4 of the VAT Act 1994 as follows 4(1) VAT shall be charged on any supply of goods or services made in the United Kingdom, where it is a taxable supply made by a taxable person in the course or furtherance of any business carried on by him. (2) A taxable supply is a supply of goods or services made in the United Kingdom other than an exempt supply. As a result there are four important conditions that have to be met if something is to fall within the scope
he transactions is that they were connected to VAT fraud. Decision 248. We find that CLL and the Dreyers were engaged in VAT fraud and that the appellant, through its director Mr Lambert, knew or ought to have known of that fraud. the second decision: establishment and place of supply 249. The Second Decision concerns whether the appellant should have charged output tax supplies of services to CLL because CLL belongs in the UK by virtue of having a fixed or business establishment in the UK. If C
Section 7(6) applies to goods whose supply involves their being imported into the UK from somewhere outside the UK. Effectively the place of supply is determined by who acts as the importer. So if the supplier imports the goods into the UK, the supply to the UK customer is treated as taking place in the UK and so the supplier may be liable to register for VAT here. Goods moving between the EU and Northern Ireland are not imports. However, if the UK customer imports the goods, the supply is treat
This covers two straightforward situations. Both serve to underline the normal principle (but see VATPOSG5000 for gas and electricity) that for goods to be taxed in the UK they must at some stage be located in the UK. Consequently a supply involving goods that remain in the UK takes place in the UK, whereas a supply involving goods that do not enter the UK takes place outside the UK. The first category describes what are often referred to as domestic supplies. It therefore covers the vast majori