Queen’s Bench Division.

Judgment delivered 4 November 1985.

Value added tax – Supply of services – Parent company entering into contracts of employment with, and paying salaries to, staff working for subsidiary company – Whether staff employed by parent or subsidiary – Whether supply of services by parent to subsidiary – Finance Act 1972, sec. 5(8) (now Value Added Tax Act 1983, sec. 3(2)(b)).

  This was an appeal by the Commissioners of Customs and Excise from a decision of the VAT Tribunal ((1984) 2 BVC 205,101) that no taxable supply of services had been made for the purposes of VAT by the taxpayer company.

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