Supply of staff or introductory services?

Adecco was an employment bureau that supplied clients with temporary staff.

The appeal concerned self-employed individuals whom Adecco introduced to clients. It accounted for VAT on the full charge clients paid for the services of the temporary workers. This comprised the amount paid by the client representing the worker’s wages and commission. The question was whether Adecco supplied staff in which case VAT should be charged on the entire fee charged to clients? Or was the supply of introductory services in which case VAT should be charged on the fee for introduction not on any amount relating to the remuneration paid to temporary workers.

Adecco had a contract with each non-employed worker under which the individual would provide services to a client through the bureau in return for payment from it. There was no contract between non-employed workers and the client. Instead there was a...