HMRC has published Revenue and Customs Brief 7 (2024) which explains:

• the VAT treatment of voluntary carbon credits from 1 September 2024
• the voluntary carbon credits that will be in the scope of the Terminal Markets Order

This is not yet fully comprehensive guidance, but does at least provide certainty in some areas.

A carbon credit is a tradable instrument issued by an independently verified carbon-crediting programme. It represents a reduction or removal of one metric tonne of carbon dioxide, or an equivalent amount of greenhouse gases from the atmosphere. Voluntary carbon credits are any carbon credits that are not compliance market credits.

Voluntary carbon credits are currently treated as outside the scope of UK VAT. This is because when they were first introduced, HMRC’s view was that they could not be incorporated into an onward supply and there was no evidence of a secondary market.

HMRC recognise that there have been significant changes in the voluntary carbon credit market, including the emergence of secondary market trading and businesses incorporating voluntary carbon credits into their onward supplies. Because of this, from 1 September 2024, the sale of these carbon credits must be treated as taxable for VAT where the place of supply is in the UK.