Supplies of staff

Produced by a Tolley Value Added Tax expert

Value Added Tax

Guidance

This guidance note provides an overview of the VAT treatment of supplies of staff and when a supply may not constitute a taxable supply of staff. This note also covers the special rules covering supplies of staff within the health and welfare sector.

What constitutes a supply of staff?

Businesses are treated as making a supply of staff when they provide one of the following to another organisation in exchange for any form of consideration:

•
an individual who is contractually employed or engaged by the business
•
a director of the business

It is not necessary for there to be a formal contract or letter of appointment for there to be a supply of staff and staff supplied on less formal basis come within the scope of these provisions.

The most important requirement is that the member of staff is not contractually employed by the recipient who receives the individual, but comes under the recipient's direction. If the business provides services, such as catering, construction and healthcare, to another party and the staff remain

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