9.7.4 Some practical reasons why the issuing of (free) vouchers in itself should not trigger VAT consequences

Besides the fact that in my view, vouchers are not the purpose of transactions that involve the use of vouchers and that, based on economic and commercial reality, transactions that involve the use of vouchers should not be treated differently (from a VAT perspective) than the exact same transactions that don’t involve or require vouchers, I will below describe additional reasons why the issuing or supply of a voucher should not trigger any VAT consequences. I will focus on the grounds for not taxing the underlying transaction when issuing an SPV, irrespective of whether it is issued free of charge or for consideration. Obviously, I understand that from 1 January 2019 these transactions trigger VAT consequences, but in my view, under desired or appropriate law, this should not be the case.