Readers' forum: Place of supply

I have been asked to provide inheritance tax advice in connection with the estate of an English lady who emigrated from the UK to Australia some ten years ago. Unfortunately she died there recently.

In her will she appointed her UK resident brother as executor. A firm of Sydney lawyers is applying for probate in Australia on behalf of the executor. The main assets of the estate are realty in the UK and in Australia.

HMRC’s VAT Place of Supply of Services Manual at VATPOSS13250 says that the services of accountants acting for executors or trustees in the general administration of winding up a foreign estate are seen as supplied to whoever is appointed executor or administrator.

However if my contract is with the Sydney law firm rather than directly with the executor is the place of supply of my services in Australia or in the UK? And does...