Securitisation / Receivables

15/11/1996

Query

VAT Treatment of the sale to a third party bank of the right to receive money due in respect of rentals on a leasing agreement.

Decision

The sale of the right to receive future rentals is an exempt supply, the taxable event only coming into play on payment of the lease payments but in the circumstances of the case due to the time factor before such payments would be made and the fact that the taxable transactions take place within a VAT group Revenue agreed that the consideration received in respect of the sale of the right to be an advance payment of lease rentals and liable to VAT.

Value Added Tax

Section 3, Value Added Tax Act, 1972

Origin: Indirect Taxes Policy and Legislation

File ref:A/421




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