The supplies described in the headings below amount to a 'supply of goods'1, unless they are specifically excluded from this category and treated as either a supply of services2 or as neither a supply of goods nor a supply of services3.
Transfers of the whole property in goods
The UK VAT legislation4 confirms that any transfer of the whole property in goods is a supply of goods.
The term 'whole property' appears to encompass all rights derived from ownership. In short, all the rights of ownership existing in the goods must be transferred without retaining any reversionary right. 'Property' means ownership, or general property. Provided that the seller contracts to transfer that interest to the buyer, the agreement is a contract of sale.
This interpretation gains support from the relevant EU law, including Archived Directive 2006/112/EC (that is, the Directive as it stood at Brexit IP completion day5), which provides that 'supply of goods' means the transfer of the right to dispose of tangible property as
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Web page updated on 17 Mar 2025 13:38