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To make matters worse the VAT regime for journey brokers is completely different – and it’s not always clear through which capacity a journey business is appearing. There is a rising physique of case law created by HMRC’s largely unsuccessful makes an attempt to argue that intermediaries are liable to VAT below the TOMS slightly than as brokers. The VAT regime has not kept pace with adjustments within the structure of the provision chain – for example travel agents offering dynamic packaging and changes in the regulatory regime including the Package deal Journey rules.

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