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Tour Operators Margin Scheme (TOMS) ― structuring considerations

Produced by a Tolley Value Added Tax expert
Value Added Tax
Guidance

Tour Operators Margin Scheme (TOMS) ― structuring considerations

Produced by a Tolley Value Added Tax expert
Value Added Tax
Guidance
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This guidance note looks at a potential structuring considerations associated with mitigating VAT costs under the Tour Operators Margin Scheme (TOMS).

For an overview of the TOMS more broadly, see the Tour Operators Margin Scheme (TOMS) ― overview guidance note.

For further commentary on the TOMS, see De Voil Indirect Tax Service V3.591–V3.594.

Wholesale supplies

This guidance note refers to wholesale supplies in relation to the transport company scheme and business to business supplies, which are dealt with under separate headings below. Supplies of designated travel services that are supplied to a business customer for subsequent resale are known as wholesale supplies.

Information about what is meant by designated travel services is provided in the Tour Operators Margin Scheme (TOMS) ― supplies covered by the scheme guidance note, under the heading: When are supplies covered by the TOMS?

The general position is that designated travel services are within the scope of the TOMS regardless of whether the recipient of the supply is in business or not and regardless of whether

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