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HMRC have issued a consultation document, 'VAT and Vouchers', which is the first step in the transposition of the EU Vouchers Directive 2016/1065, into UK VAT law.

The EU Vouchers Directive was agreed on 27 June 2016 and will take effect in relation to vouchers issued on or after 1 January 2019. The UK will introduce these rules into UK law.

Single purpose vouchers (SPVs)

Multi-purpose vouchers (MPVs)

Intermediaries and agents

Part payment

The consultation will run until 23 February 2018 and draft legislation will be published in Summer 2018 for inclusion in Finance Bill 2018-19. The full document can be found here.


Summary of questions:

Definition of a voucher

Q1. These new rules do not include transport and admission tickets, postage stamps, or the electronic products and payment mechanisms referred to above. Does this cause any difficulty to your business or organisation?

Q2. These new rules do not include on-line credits and telephone SIM cards. Does this raise any concerns for your business or organisation?

Q3. Will applying the new definition of a voucher increase the administrative burdens or cost for your business? Please provide details of both one-off and ongoing costs.

Single Purpose Vouchers SPVs

Q4. Are there any concerns over the wider definition of an SPV that you wish to bring to our attention?

Q5. Are there any concerns over the taxation of SPVs that you wish to bring to our attention?

Q6. Will applying the new rules for SPVs increase the administrative burdens or cost for your business? Please provide details of both one-off and ongoing costs.

Multi-Purpose Vouchers MPVs

Q7. Are there any concerns over the valuation of goods and services, provided in respect of MPVs when they are redeemed, that you wish to bring to our attention?

Q8. Will applying the new rules for SPVs increase the administrative burdens or cost for your business? Please provide details of both one-off and ongoing costs

SPV intermediaries

Q9. Are there any concerns over the position of intermediaries that you wish to bring to our attention?

Q10. Do you agree that the existing rules in section 47 of the VAT Act 1994 are sufficient to accommodate the requirements of the Directive?

MPV intermediaries

Q11. Some distributors may wish to change from a buy/sell arrangement to an agency arrangement. This would allow them to charge commission and deduct VAT under normal rules. It would also allow the price paid by the final buyer to be identified. Do you think that the new rules for the treatment of intermediaries will lead to you changing your business model in the way described above?

Q12. Are there any concerns over the position of intermediaries transferring MPVs that you wish to bring to our attention?

Q13. Will applying the new rules for the treatment of intermediaries increase the

administrative burdens or cost for your business? Please provide details of both one-off and ongoing costs.

Part payments

Q14. Will applying these rules for part payments increase the administrative burdens or cost for your business? Please provide details of both one-off and ongoing costs.

Retail Schemes

Q15. Will applying the rules for vouchers to your retail scheme increase the administrative burdens or cost for your business? Please provide details of both one-off and ongoing costs.

Vouchers issued before 1 January 2019

Q16. Will retaining Schedule 10A for vouchers issued before 1 January 2019 create any difficulty for your business or organisation?

Vouchers issued after 1 January 2019

Q17. Are there any concerns over timing that you wish to bring to our attention?