9.8.7 Conclusion regarding the applicability of a VAT exemption

In my view, taking all the above into account, the arguments against the application of an exemption to voucher transactions are much stronger than the arguments for an exemption. Therefore, transactions regarding ‘payment vouchers’ should in my view be subject to VAT, unless they’re outside the scope of VAT. However, this can be different for certain specific services aimed at specific parts of a transaction, i.e. the transfer of funds as payment for a supply. As a main rule, distribution services regarding vouchers are not exempt.