Value Added Tax Act 1994 section 47

Agents etc.

Section 47 deals with how VAT applies when goods or services are supplied through agents who act in their own name rather than in the name of the person they represent.

• When a taxable person imports goods as agent for a non-taxable person and acts in their own name, the import and supply are treated as made by the agent as principal for VAT purposes.
• Where goods not covered by the import rule are supplied through an agent acting in their own name, the transaction is split into two supplies: one to the agent and one by the agent.
• For most services (excluding electronic and telecoms services), HMRC has discretion to apply the same two-supply treatment when an agent acts in their own name.
• For electronically supplied services and telecommunication services provided through an agent acting in their own name, the two-supply treatment applies automatically.