VATGPB8860 – Other local authority activities: miscellaneous (N to Z): supplies of staff
Basic principles
A section 33 body (see VATGPB4000) that supplies the services of its staff under the same legal conditions that apply to the private sector is not acting in its capacity as a public authority. The supply it makes is therefore a taxable business activity.
By contrast, if the section 33 body makes the supply under a special legal regime it does so in its capacity as a public authority (see paragraph VATGPB2300) and the supply is outside the scope of VAT.
Source gov.uk
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