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Notes:
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VAT – place of supply of football agent services – transfer of player from Sporting Lisbon to Inter Milan in 2016 – were the services supplied to the player or to Inter – both – was the payment of all or part of the €4 million paid by Inter to the agent payment for services supplied to it or third party consideration for services to the player - on the facts it was for services supplied to Inter so the place of supply was Italy – alternative argument – do the intermediary provisions in Article 46 PVD and paragraph 10 of schedule 4A VATA apply – yes – consideration of Vodafone 2 Marleasing and Lipjes - no liability to VAT in the UK – appeal allowed |
