VATFIN2720 | Money (including transfer of money) and related services: foreign exchange (forex): what businesses might be involved in forex transactions?
From HM Revenue & Customs · VAT Finance Manual
When forex is mentioned many people associate such an activity with a dedicated trading operation or a Money Service Business (MSB) such as a Bureau de Change, located either in a bank, a travel agent or on the high street. However, many other kinds of business deal in forex, and not just with the public. For example:
Dedicated Market Making banks
Other banks
National Central Banks
Hedge funds
Forex brokers
Finance Houses
Insurance companies
Major corporates running ‘Treasury’ operations
Investment companies
Pension funds
Companies receiving customer settlement in, or, settling with overseas suppliers in non GBP currencies
Hotels restaurants, airlines, etc
Other
Business can conduct forex transactions as economic activities in their own right or as incidental to their main business activities. This can affect the way HMRC treats such transactions (see VATFIN2740 and VATFIN2750).
N.B. please note that this is not designed as a definitive list