Scenario
A British subscriber to UKTelCo uses his mobile phone in France. UKTelCo is collecting the payment but FranceTelco provides the service as there is a roaming agreement between the two telcos. Where is the place of supply for VAT purposes? Is it the UK where the subscriber is resident or France where the call is originated?
If UKTelco has a contract with the subscriber for the provision of telecoms services then the place of supply is the UK and UK VAT is charged on the B2C supply. The roaming agreement between the two telcos is a B2B supply of services and is not relevant to the supply by UKTelco to the subscriber.