The recent case of American Express Services Europe Limited (AESEL) v HMRC is a useful reminder of the well-established two-stage approach to determining the correct recipient of a supply of services for VAT purposes. The case also reminds us of the large degree of uncertainty surrounding the application of this approach. As we go on to discuss, this uncertainty is surprising given, as here, the VAT recoverability position of the supplier is dependent on the location of its supply.
Source: proskauer.com