Indirect Taxes

Modernising the tax system

Reform of VAT Terminal Markets Order

Last updated: 12/06/2025

  • The Terminal Markets Order (TMO) provides for the VAT zero-rating of certain wholesale commodity transactions made by members of certain commodity exchanges.
  • In July 2023, HM Treasury consulted on modernising the legislation setting out the VAT treatment of transactions within the scope of the TMO.
  • The amendments are intended to reflect how the markets now operate and provide greater certainty, without amending the policy or scope of the TMO.
  • The consultation also included proposals to include the UK Emissions Trading Scheme in the scope of the TMO.
  • Finance (No.2) Act 2024 included legislation to enable the amendment of the TMO (by way of statutory instrument).
  • The government has issued its response to the consultation, indicating that it will continue to develop the legislative framework for reform, and will engage with interested parties.
  • Timing: the government issued its response to the consultation on 28 April 2025.

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