Input tax – Disallowance – Paper purchased by advertising agency for leaflets – Whether acquired as principal, or agent for overseas client – Whether agency liable to account for output tax on payment received from client.
The issue was (1) whether the claim of the appellant to deduct input tax on the acquisition of paper should be allowed, (2) whether supplies of brochures made by the appellant were zero-rated under VATA 1983, Sch. 5, Grp. 3, item 2, or alternatively constituted zero-rated under supplies of advertising services to a customer outside the EC under Sch. 5, Grp. 9, item 6(a).
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