9.7 The issuing and transfer of vouchers should not be subject to VAT

Based on the my research of the appropriate VAT treatment of voucher transactions in Sections 9.1 to 9.6, I come to the conclusion that under appropriate law, issuing and transferring vouchers should not be subject to VAT. In this Section (9.7) I will provide additional basis for that conclusion.

Not only the issuing of a voucher, but also the (subsequent) transfer of a voucher by someone else than the issuer should, in my view, not be considered a transaction that is subject to VAT: a voucher, in my view, is never the actual ‘purpose’ or ‘object’ of a voucher transaction, as I explained in Section 9.3.3. Also, the issue or transfer of a voucher should, in my view, not be considered a ‘separate’ transaction ‘in its own right’, but rather a step in or towards the supply of goods or services that that it relates to, meaning that the issue or transfer as such should not be subject to VAT.

It can be argued that this is different for certain types of voucher, for example where a voucher that is issued for consideration entitles the holder a discount to multiple (or an unlimited amount of) transactions at a specific (chain of) shop(s), e.g. for a certain period of time, or where a business sells a voucher that can be redeemed for goods or services at another business and these businesses do not pay or settle any amounts between them.1 However, I would argue that even in these cases, the voucher is only a means to prove that said right to discounts or supplies exists, rather than the object of the transaction. The (taxable) transfer of the right to those discounts happens to be transferred at the same time as the instrument that is used as proof of entitlement to those rights. Conceptually, these ‘rights’ could also be transferred and proven by electronic means, e.g. by storing the relevant details of the holder to those rights to be checked upon use or redemption, proving that the voucher itself is not the object or aim of the transaction.