Changes to Time of Supply Rules

The rule changes taking place in 2010 cover notbusinesses that the new rules may involve. It is
only the place of supply, but also the time of supply.expected that the legislation will all be in place before
It means that the time at which VAT must beParliament rises for the Christmas recess.
accounted for under the reverse charge changed on 
1 January 2010. The changes will be introduced byThe guidance explains in detail how the new rules will
secondary legislation later in the year.apply to single supplies of services and continuous
 supplies of services and how to define tax points in
This is being done to “harmonise the time ofboth cases. For example, with a single supply the tax
supply rules for reverse charge services throughoutpoint will be completion of the service, and for
the EU” – in other words, to make rulescontinuous supplies there will be a tax point at the
applied to cross-border supplies of services byend of each billing or payment period. The difference
different Member States more consistent.between single and continuous supplies of services is
 explained in detail. Other answered questions include:
HMRC has made the following Place of Supply/Time- What supplies are affected?
of Supply guidance available on its website. Part 4 of- Why do the new rules cover all supplies subject to
the document answers several important (andthe reverse charge arrangements in the UK?
probably frequently asked) questions regarding the- How will I treat supplies that span 1 January 2010?
forthcoming time of supply rule changes.- What impact will these rules have on completion of
 UK EC Sales Lists?and a few more.
The time of supply changes came into effect at the 
same time as other VAT Package changes on 1I will be writing more articles on these topics over
January 2010, though some legislation is still in draftthe coming weeks and months. For now, I
and consultations with business groups have beenrecommend that you read the guidance available
taking place to minimise additional burden onfrom HMRC.