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The Value Added Tax (Fiscal Warehousing) (Treatment of Transactions) Order 1996
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3.—(1) A transaction fulfilling the description set out in paragraph (2) below shall be treated as a supply of goods and not as a supply of services.
(2) The description referred to in paragraph (1) above is that there is a supply (which is not a retail transaction) involving the transfer of any undivided share of property in eligible goods and either—
(a)that supply takes place while the goods in question are subject to a fiscal warehousing regime, or
(b)the transferee causes the goods in question to be placed in a fiscal warehousing regime after receiving that supply but before the supply, if any, which next occurs involving the transfer of any property in those goods.
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