Under the current EU place of supply rules, where a UK business supplies services to EU consumers via the internet that require a degree of human intervention to deliver, such services are classed as being supplied where the supplier is established for VAT purposes. 

From 1 January 2025, the place of supply rules for EU VAT at article 53 to the EU VAT directive change to make supplies of admission services to any events delivered using the internet or other digital media to EU consumers, subject to EU VAT in the country where the customer is established. This will affect a wide range of UK suppliers who use the internet to deliver live-streamed events to their customers.

It will also cause a double VAT exposure where from HMRC’s perspective the place of supply is the UK and thus subject to UK VAT and where the EU’s view is the place of supply it is subject to EC VAT.

As an example:

Until 1 January 2025  a UK-limited company delivering teaching as a one-off event live-streamed to an EC consumer would account for UK VAT (assuming the supplier is not an eligible body for the purposes of the education exemption). It will not have an EU VAT liability.

From 1 January 2025  the same supplier will have :

• a UK VAT liability as the place of supply as far as HMRC is concerned is the UK and
• an EU VAT exposure as the place of supply is the EU as far as the European tax authorities are concerned.

The further issue is the fine line between a supply that is classed as admission to an educational event (or series of events) compared to a supply of education that will remain classed as supplied where the education takes place – which in the UK’s case takes place in the UK if the education is delivered online.

If you or your client are impacted by the above changes, please contact our firm on 0161 477 6600 or use our online enquiry form for an initial discussion.