VATPOSS05350 - Establishment making or receiving the supply: Global contracts
In order to determine the place of supply of a global contract, it is important to first of all distinguish between a global contract that forms a single supply for VAT purposes and a global framework agreement, often between the business head office and a supplier, that sets the terms for a number of individual supplies.
For example, a business could enter into a contract for a single supply of consultancy services. »Ê¹ÚÌåÓýapp consultancy services analyse the global set-up and business practices at the head office and overseas branches. HMRC would regard this as a global contract with a clear direct benefit to the business as a whole, including a number of establishments. In this scenario the services would be supplied to the main business establishment.
Where a framework agreement exists it is important to look at the individual transactions which, as separate supplies, will have separate treatments for VAT purposes. For example, a head office of a business could enter into a framework agreement with a global firm of consultants. »Ê¹ÚÌåÓýapp agreement specifies the fees, terms and conditions. Individual branches then draw up and purchase work from the local branches of the consultant under the terms of the framework. »Ê¹ÚÌåÓýappse services will be viewed as supplied to the branches even if the head office dictates the terms and receives an indirect benefit.