VATFIN2815 - Money (including transfer of money) and related services: securities for money, credit guarantees and related services: legal provisions
Article 135.1 (c) of the Principal VAT Directive exempts:
the negotiation of or any dealings in credit guarantees or any other security for money and the management of credit guarantees by the person who is granting the credit
The above has been enacted into UK law as the VAT Act 1994, Schedule 9, Group 5, item 1, which exempts:
1. The issue, transfer or receipt of, or any dealing with … any security for money or any note or order for the payment of money
Notes (1) and (1A) to Group 5, state:
(1) Item 1 does not include anything included in item 6.
(1A) Item 1 does not include a supply of services, which is preparatory to the carrying out of a transaction falling within that item.