Value Added Tax Act 1994 section 18

Place and time of supply

Section 18 sets out the VAT treatment of goods held under warehousing regimes, determining when and where supplies of those goods are treated as taking place, and who is liable to pay any VAT due.

  • Supplies of imported goods held under a warehousing regime are generally treated as taking place outside the UK, provided the goods have not been mixed with UK-produced dutiable goods and the supply occurs before the duty point
  • Supplies of UK-produced dutiable goods (or mixtures containing them) held under a warehousing regime can also be treated as outside the UK, but only if there is a subsequent supply of those goods that also takes place while they remain warehoused and before the duty point
  • When a warehoused supply is ultimately treated as taking place in the UK, the time of supply is the earlier of when the goods leave the warehousing regime or the duty point, and VAT must be paid at that time by the person removing the goods or by the person liable for the duty or levy
  • HMRC may make regulations allowing taxable persons to defer payment of VAT arising on removal from warehousing, for example by including it in their normal VAT return or alongside deferred excise duty payments

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