In some instances, employment visas are held by one person (e.g. company) while the employees work under the supervision and control of another person.
Supervision and control of employees refer to an employer being responsible for deciding on the place of work of the employee, assigning employees their work tasks, and evaluating/assessing their performance.
These supplies can either be classified as manpower services (identifying/recruiting/hiring candidates and making such employees available to work for another entity) or visa facilitation services (administrative services to merely facilitate the employment visa process for employees hired by another entity without making its employees available to that other entity).
Companies are facing challenges in determining the nature of the supply (i.e. whether it is a supply of manpower or visa facilitation services), and how to determine the value of these supplies for VAT purposes, especially where they are part of the same corporate group.
This Public Clarification provides guidelines on determining the nature of these supplies as well ...