The Revenue have issued eBrief No.14/2007 which deals with the VAT treatment of certain secondments of staff to companies established in the State from related foreign companies.

In summary, for VAT purposes, the provision of staff is a supply which is taxable where received-paragraph (vi) of the Fourth Schedule to the Value-Added Tax Act 1972.

In certain circumstances, with effect from 1 January 2007, Revenue is prepared to sanction the following concessionary treatment:

To the extent that the emoluments paid to the employee in respect of work done in the secondment period form the consideration, or part of the consideration, for the secondment of the employee to the company/branch, they shall be disregarded in determining the value for VAT purposes of seconding the employee.

A copy of the eBrief is reproduced at Section 2.06.