“ 39. Any transaction, which is not a supply of goods, is a supply of services and, if for consideration, is subject to VAT unless exempt (Articles 24(1) and 2(1)(c) and Chapters 2 to 9 of Title IX of the Principal VAT Directive). The CJEU has held that a supply of services for consideration requires a legal relationship between the provider of the service and the recipient pursuant to which there is reciprocal performance, the remuneration received by the provider of the service constituting the value actually given in return for the service supplied to the recipient (Case C-16/93 Tolsma v Inspecteur der Omzetbelasting Leeuwarden[1994] STC 509 at [14]). Although the CJEU in Tolsma used the term ‘legal relationship’, that should be understood, in the light ofCase C-498/99 Town and County Factors Ltd v Customs and Excise Commissioners[2002] STC 1263 at [21] - [24], as including a reciprocal arrangement under which the service provider’s obligations are not legally enforceable but are binding in honour only. … 42. The contractual arrangements introduced by DPAS from1 January 2012 are, on DPAS’s case, tripartite arrangements. Lord Millett observed in Customs and Excise v Plantiflor Ltd[2002] STC 1132 at [49] that tripartite arrangements which result from two or three separate but related bilateral contracts call for close analysis in order to determine their tax consequences. As Lewison J explained in A1 Lofts Ltd v HMRC[2009] EWHC 2694 (Ch) ,[2010] STC 214 at [40], quoted with approval by Lord Neuberger in Secret Hotels2 Ltd v HMRC[2014] UKSC 16 ,[2014] STC 937 at [32], the starting point is to identify the legal rights and obligations of the parties as a matter of contract before going on to classify them. This starting point is a matter of domestic law. ” 66. In the light of these authorities Mrs Brown correctly submitted that the legal relationships in their widest sense must be analysed. It is necessary to consider what the agents are doing for the University and the students, when they are doing it and how they are remunerated for it. 67. It was not clear to me that Mrs Brown was relying on the existence of a contractual duty on agents to provide advice and assistance to students as well as economic reality. In other words, both limbs described by the Supreme Court in Airtours. She did submit that “if something is done for somebody and it is paid for, through the eyes of the supplier there will be a supply for VAT purposes”
“ Article 43 The place of supply of services shall be deemed to be the place where the supplier has established his business or has a fixed establishment from which the service is supplied, or, in the absence of such a place of business or fixed establishment, the place where he has his permanent address or usually resides. Article 44 The place of supply of services by an intermediary acting in the name and on behalf of another person, other than those referred to in Articles 50 and 54 and in Article 56(1), shall be the place where the underlying transaction is supplied in accordance with this Directive. ” 87. As stated above, the effect of the general rule was that the place of supply was deemed to be the place where the supplier was established. In the case of the agents, that was outside the EU so that if this argument is right no VAT would be chargeable up to1 January 2010 . The Appellant also argues that Article 44, which operated as a carve out to exclude the general rule in the case of intermediaries supplying services and acting in the name and on behalf of another person, was not applicable. Firstly, because the agents did not act in the name and on behalf of the University; secondly, because Article 44 only applies where the services supplied by the intermediary relate to an underlying supply of goods from principal to consumer. I deal with the two arguments separately. (1) Did agents act in the name and on behalf of the University? 88. The Appellant argues that the description of a person acting “in the name and on behalf of another person” has a specific meaning as a matter of EU law and has nothing to do with the concept of “agency” in UK domestic law. In particular, it requires the intermediary to be able to bind the other person through its conduct and actions. In support of that submission Mrs Brown relied on the following decisions of the CJEU. 89. In De Danske Bilimportorer v SkatteministerietCase C-98/05 the CJEU was concerned with registration duty for new cars, and whether it should be included in the taxable amount for VAT purposes. The purchaser of a new vehicle contended that it should be excluded from the taxable amount as it was a disbursement paid by the dealer on behalf of the purchaser, relying on Article 11(A)(3)(c) of the Sixth Directive which provided as follows: “ The taxable amount shall not include: … (c) the amounts received by a taxable person from his purchaser or customer as repayment for expenses paid out in the name and for the account of the latter and which are entered in his books in a suspense account … ”
“ 40. In law the question must be answered by reference to Article 11(A)(3)(c) of the Sixth Directive, that is to say, the Community law notion of acting in the name and for the account of another and not by reference to civil law provisions concerning agency and mandate which vary from one legal system to another. 41. Moreover, the operation must be categorised by reference to objective criteria and not solely to contractual provisions agreed between the dealer and the purchaser. Otherwise the parties could determine which elements are included in the taxable amount ” 92. A similar issue was considered by the CJEU in TVI Televisao Independente SA v Fazenda PublicaCase C-618/11 which concerned a “screening tax” imposed on the screening and broadcasting of advertising which was charged to advertisers but paid to the Portuguese tax authorities by service providers. The case also concerned the application of Article 11(A)(3)(c) Sixth Directive. The CJEU adopted the approach of Advocate General Kokott in Bilimportorer. On the facts the service provider was the “tax debtor”, it was required to pay the tax even if the advertisers had not paid for the screening services in question, and the tax authorities could not claim the tax from the advertisers. The CJEU held that it followed “that [the service provider] pays the tax in its own name and on its own behalf”
“ professional activities of persons instructed under one or more contracts or empowered to act in the name and on behalf of , or solely on behalf of, one or more insurance undertakings, in introducing, proposing and carrying out work preparatory to the conclusion of, or in concluding, contracts of insurance … ” 96. Before considering the decision of the CJEU in Arthur Andersen, it is helpful to consider a previous decision of the Court in Taksatorringen v SkatteministerietCase C-8/01 . In Taksatorringen the CJEU was concerned with the same exemption from VAT for related services performed by insurance brokers and insurance agents. The taxpayer was in business assessing damage to motor vehicles on behalf of insurance companies and one of its arguments was that its activities were those of an insurance agent. At [45] the CJEU declined to rule on whether the term “insurance agent” in Article 13B(a) Sixth Directive was to be construed in the same manner as the Insurance Directive, because even if it was the taxpayer’s activities did not fall within Article 2(1)(b) Insurance Directive as it did not have power to render the insurer liable in respect of an insured person who had incurred a loss. By implication therefore the CJEU must have considered that the same requirement applied to the term insurance agent in the Sixth Directive. The CJEU endorsed what was said by the Advocate General where at [91] of his opinion he stated: “ In order for this assistance to be provided by an insurance agent, however, it must be given within the context of a contract or an authority to act and ‘in the name and on behalf of, or solely on behalf of, one or more insurance undertakings’. There must therefore be a power to bind the insurance company in relation to an insured person who has submitted a claim. Once again, this requirement is not met by Taksatorringen. ” 97. In Arthur Andersen the taxpayer argued that its activities were identical to those described in Article 2(1)(b), and emphasised that it had power to render the insurance company liable with regard to insured parties and beneficiaries. The CJEU noted at [31] and [32] that the Court in Taksatorringen had held that Article 2(1)(b) Insurance Directive required the existence of a power to render the insurer liable. However, that was not the determining factor for recognition of an insurance agent within Article 13B(a) Sixth Directive. It was still necessary to examine the nature of the activities carried out and the activities of Arthur Andersen, whilst contributing to the activities of an insurance company, did not constitute services which typified an insurance agent. Essential aspects of the work of an insurance agent such as finding and introducing prospects to an insurer were lacking. 98. In both these cases one might generally describe Arthur Andersen and Taksatorringen as “intermediaries”, but the question being considered by the CJEU in each case was whether the taxpayer was an insurance agent. In neither case was the taxpayer an insurance agent. In Taksatorringen because there was no power to bind the insurer and in Arthur Andersen because the activities were not those of an insurance agent. 99. The words “in the name and on behalf of” are used in the Insurance Directive in the context of insurance activities. However, it seems to me that they are familiar words of general application. It does not seem to me that there is any reason why they should have one meaning in the context of the Insurance Directive and another meaning in the context of Article 44 PVD. Mr Mandalia did not suggest any reason as to why they should have a different meaning. He did not distinguish between the different contexts in which the words appeared. He did however invite me to give Article 44 a purposive construction and criticised Mrs Brown for adopting a literal approach to the construction of Article 44. In identifying the purpose of Article 44 he took me to the preamble of the Principal Directive, emphasising in particular the common system of VAT and fiscal neutrality, both in terms of competition and the burden of the tax. 100. Against that background Mr Mandalia submitted that the particular purpose of Article 44 was to promote the overarching concept of fiscal neutrality. He gave an example of someone using an intermediary to recruit employees from around the world. If the Appellant’s argument was right the employer would have to pay VAT if using an EU based intermediary but not if using an intermediary from outside the EU even if recruiting the same employees. He submitted that the non EU based intermediary had a competitive advantage. 101. It does not seem to me that the Appellant’s argument gives rise to any breach of the principle of fiscal neutrality. As Mrs Brown submitted, distortions of competition may arise inherently from the way in which a Directive is drafted – see for example Bridport and West Dorset Golf Club Ltd v Commissioners for Revenue & CustomsCase C-495/12 . It must also be remembered that the general place of supply rule in Article 43 is that a supply takes place where the supplier belongs. In cases where an intermediary is in a position to bind its customer, then the service supplied by that intermediary should be an exception to the general rule. The intermediary has a closer connection with the EU than an intermediary with no power to bind the customer. To use Mrs Brown’s words, if an agent were able to bind the University then the supply by the agent would be “tethered” to the University. 102. Support for that being a significant distinction may be found in analysing the CJEU decision of Staatssecretaris van Financien v LipjesCase C-68/03 . See [128] of my analysis of that decision in the context of the second Intermediary Argument. 103. Mr Mandalia submitted that agents, by virtue of their relationships with the University and students, were able to encourage suitably qualified students to apply for courses with the University. As I understand the submission, an agent was plainly intermediary in the sense that it facilitated the transaction. Mr Mandalia’s submission was that as a matter of ordinary language, agents acted in the name and on behalf of the University. They were the University’s face abroad promoting the University and using the University’s marketing materials. However, that argument gives no legal content to the requirement that the intermediary must be acting “in the name and on behalf of” another person. In my view they are words which must be given some legal meaning. 104. Mr Mandalia relied on the exclusion from Article 44 of supplies referred to in Articles 50, 54 and 56 PVD which provide as follows: “ Article 50 The place of supply of services by an intermediary, acting in the name and on behalf of another person, where the intermediary takes part in the intra-Community transport of goods, shall be the place of departure of the transport. [unless the customer of the services is identified for VAT purposes in a Member State other than that of the departure in which case it is deemed to be the Member State of the customer] Article 54 The place of supply of services by an intermediary, acting in the name and on behalf of another person, where the intermediary takes part in the supply of services consisting in activities ancillary to the intra-Community transport of goods, shall be the place where the ancillary activities are physically carried out. [unless the customer of the services is identified for VAT purposes in Member State other than the place where the ancillary activities are carried out in which case it is deemed to be the Member State of the customer] Article 56 The place of supply of the following services to customers established outside the Community, or to taxable persons established in the Community but not in the same country as the supplier, shall be the place where the customer has established his business or has a fixed establishment for which the service is supplied, or, in the absence of such a place, the place where he has his permanent address or usually resides: [(a) – (k) sets out various specific services such as advertising services, professional services and telecommunications services]… (l) the supply of services by intermediaries, acting in the name and on behalf of other persons, where those intermediaries take part in the supply of the services referred to in this paragraph. ” 105. As I understand the submission, in the context of the transport of goods an intermediary would be able to bind anyone, so the words “in the name and on behalf of” would be superfluous. It is not clear to me why the intermediary in that case would be able to bind anyone. Nor was it clear to me how Mr Mandalia said that the exclusion of Articles 50, 54 and 56 sheds any light on the meaning of the words “in the name and on behalf of” in Article 44. 106. Mr Mandalia relied on a decision of the F-tT in Firstpoint (Europe) Limited v Commissioners for HM Revenue & Customs[2011] UKFTT 708 (TC) . In that case the tribunal was concerned with the amended version of Article 44 (now Article 46). The amended version reads as follows: “ The place of supply of services rendered to a non-taxable person by an intermediary acting in the name and on behalf of another person shall be the place where the underlying transaction is supplied in accordance with this Directive. ” 107. The facts of Firstpoint concerned a consultancy providing guidance and advice to students pursuing sports scholarships to colleges in the United States. It is clear that the F-tT found at [47] that the taxpayer met the criteria of Article 46, however there was no finding to the effect that the taxpayer could bind anyone. In relation to the words “in the name and on behalf of another person” the F-tT simply said this at [48]: “ 48. … As well as that the intermediary must also act in the name of and for another person. The Tribunal took the view that is simply ensuring he cannot act as a principal or undisclosed agent. ” 108. It is not clear to me why the F-tT in Firstpoint made reference to undisclosed agents. That is a concept of the law of agency in England and Wales and Mr Mandalia did not rely on the distinction between disclosed and undisclosed agents. In any event, there was no detailed consideration by the F-tT as to the meaning of “in the name and on behalf of”
“ By way of derogation from Article 9(1), the place of the supply of services rendered by intermediaries acting in the name and for the account of other persons, when such services form part of transactions other than those referred to in paragraph 1 or 2 or in Article 9(2)(e), shall be the place where those transactions are carried out. ”
“ 23. Generally speaking, intermediary services are supplied in the place where the supplier has established his place of business … That rule embodies the principle of taxation in the country of origin and makes it possible to locate the activity giving rise to the tax obligation in a particular territory and to identify the applicable national legislation. 24. The point of reference is transferred from the place of establishment of the supplier of the service to that of the customer where an intermediary acts in connection with the transactions referred to in art 9(2)(e), and those transactions are carried out on behalf of persons established in another country. 25. An exception to the general rule also applies where a third party acts as an intermediary in the intra-Community transport of goods or in services ancillary thereto, in which case the taxable transaction is deemed to occur in the place of the principal activity, in other words, in the place where the transport of the goods begins or the place where the ancillary activity is carried out, respectively. However, if the service is performed on behalf of a customer who uses in the transaction an identification number for VAT purposes which was issued by another member state, the territory of that member state becomes the point of reference for determining the place where the taxable transaction is performed. 26. Finally, the same criterion applies to establishing the place of the taxable transaction in relation to other types of intermediary services in the trade of goods between member states, in other words, it is the place of the transaction in connection with which the intermediary acts, subject to the exception referred to above in cases where the principal is registered for VAT in another member state. 27. To summarise, the services of an intermediary are subject to tax in the member state where: 1. the intermediary is established (the general rule laid down in art 9(1)) j ; 2. the customer is established (final indent of art 9(2)(e)); 3. the activity in connection with which the intermediary acts is carried out (first sub-para of art 28b(E)(1), (2) and (3)); or 4. the customer has a VAT identification number which is used in the transaction (second sub-para of art 28b(E)(1), (2) and (3)). 28. The situation in the main proceedings, where an intermediary acted on behalf of two individuals resident in the Netherlands in the acquisition of two yachts located in France, is only capable of being covered by the first or the third possibility. j It appears that the Commission was mistaken in its assertion that art 9(1) does not apply to intermediary transactions. On the contrary, as I have just noted, that provision sets out the main criterion. The final indent of art 9(2)(e) refers only to activity by an intermediary on behalf of persons established in another country where that activity relates to certain services. For its part, art 28b(E) concerns the activities of intermediaries in the intra-Community acquisition and transport of goods. All other intermediary activities are subject to art 9(1) . ” (Emphasis added)