V4.156 Exemption—trade union, professional and public interest bodies
EU legislation
The purpose of this exemption is set out in a commentary to the first report of the European Commission on what was to become the Sixth Directive. It states:
'…these organisations are in fact acting as the collective voice of their members and the subscriptions paid by the latter are for membership of a collective organisation and do not represent a consideration for services rendered. Such organisations should therefore fall outside the scope of VAT'.
It follows, and it has been held, that where the organisation in question does more than act as the collective voice of its members, eg by providing services to its members, it does not (or may not) fall within the exemption1.
The exemption extended to the subscription income of certain bodies is derived from Archived Directive 2006/112/EC, art 132(1)(l), which exempts:
'the supply of services, and the supply of goods closely linked thereto, to their members in their common interest in return for a subscription
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