In Phone Nation v HMRC [2015] UKFTT 593 (25 November 2011) the FTT found that Phone Nation had not been making taxable supplies; however it was still liable for any VAT invoiced to customers.
The issue was whether companies such as O2 and Vodafone made direct supplies of top-up vouchers to ultimate phone customers and users with two intermediate companies (one being Phone Nation) simply acting as agents; or whether the vouchers were supplied to each of those intermediates in turn so that Phone Nation was both receiving and making supplies.
The chain of supplies worked as follows. A customer would for example pay £10 to Phone Nation. Phone Nation would then extract from a machine provided by ePay (a distinct company) a receipt with a code number. The customer then keyed this code into his phone to add the...
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In Phone Nation v HMRC [2015] UKFTT 593 (25 November 2011) the FTT found that Phone Nation had not been making taxable supplies; however it was still liable for any VAT invoiced to customers.
The issue was whether companies such as O2 and Vodafone made direct supplies of top-up vouchers to ultimate phone customers and users with two intermediate companies (one being Phone Nation) simply acting as agents; or whether the vouchers were supplied to each of those intermediates in turn so that Phone Nation was both receiving and making supplies.
The chain of supplies worked as follows. A customer would for example pay £10 to Phone Nation. Phone Nation would then extract from a machine provided by ePay (a distinct company) a receipt with a code number. The customer then keyed this code into his phone to add the...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
