Following the ECJ decision of Lebara Ltd, HMRC have acted quickly to amend the way VAT is accounted for on Single Purpose Vouchers, it would seem as almost a given that mobile phone top up vouchers should be considered as single purpose vouchers as the Lebara case was based totally upon this assumption .
I am however yet to see a mobile top up voucher that invoices for VAT, recent VAT receipts from the Vodafone and O2 stores still shows zero rated in the VAT column.
I have concluded either;
Lebara vouchers were considered single purpose vouchers because services such as premium rate calls and SMS are barred, this means the credit can only be used for calls and SMS not for the purchase of games and ringtones. With Vodafone vouchers in addition to calls and SMS the credit can be used for the purchased of games and ringtones albeit though the process of call or SMS (premium rate).
Revenue & Customs Brief 12/12 1.2 allowed for businesses to make intimidate changes or continue as is and make an adjustment to cover the intervening period. It could be the Vodafone has decided to make this adjustment in the future.
I would be very interested if anyone has an opinion on the matter.