Value Added Tax Act 1994, Schedule 10A, paragraph 2

Nature of supply

SCHEDULE 10A Face-value vouchers issued before 1 January 2019

2 The issue of a face-value voucher, or any subsequent supply of it, is a supply of services for the purposes of this Act.

Definitions used in Schedule 10A, paragraph 2 2

face value voucher

“face value voucher” has the meaning given by paragraph 1(1) above;

Defined in Sch.10A para.8(1) · see it in the full Act
face-value voucher

1 (1) In this Schedule “face-value voucher” means a token, stamp or voucher (whether in physical or electronic form) that represents a right to receive goods or services to the value of an amount stated on it or recorded in it.

Defined in Sch.10A para.1(1) · see it in the full Act

Cases considering Schedule 10A, paragraph 2 5

Arachchige v Revenue and Customs

[2010] EWCA Civ 1255 · 8 November 2010

Paragraph 2 treated the issue or subsequent supply of a face-value voucher as a supply of services. That classification supported treating the phone-card transaction as a service rather than merely a transfer of a right. (see para [15])

HM Revenue & Customs v Prince Karunaraina Samarappulli Arachchige

[2009] EWHC 1077 (Ch) · 20 May 2009Defines

The provision treats the issue and subsequent supply of a face-value voucher as supplies of services. It establishes the statutory character of the respondent’s transactions. (see paras [11]-[12])

Associated Newspapers Ltd v HM Revenue & Customs

[2017] EWCA Civ 54 · 10 February 2017Defines

Paragraph 2 classifies the issue and subsequent supply of a face-value voucher as a supply of services. The court applied that starting point, subject to the special rule for directly issued retailer vouchers in paragraph 4(2) (see paras [29]; [76]-[79]).

What each judgment says about Schedule 10A, paragraph 2 is in the case-law panel in the full Act.