9.5.2.10 The VAT treatment of issuing and transferring MPVs

Under Article 30b(2) of the EU VAT Directive, the issue or transfer of an MPV shall not be subject to VAT. Where a transfer of an MPV is made by a taxable person other than the taxable person that issued the voucher and that actually hands over the goods or actually provides the services in return for the MPV (accepting it as consideration or part consideration), any supply of services that can be identified, such as distribution or promotion services, shall be subject to VAT.

This means that issuing and transferring MPVs is not subject to VAT, unless a specific service, such as a distribution service or a promotion service, is specifically agreed and made for consideration. This means that from an EU VAT perspective, it is irrelevant whether MPVs are issued for consideration or not, because the issue or transfer as such is not subject to VAT.1

This VAT treatment is in line with the purpose of EU VAT, since no expenditure is made (yet) for local private consumption, which means no taxation should occur (yet). Also, the economic and commercial reality of issuing MPVs is that no actual supplies are made (yet), which confirms that no taxation should occur at this stage of the voucher transaction chain.