LON (89/695)

No. 4575

Decision given 15 February 1990.

Credit notes – Issued bona fide and not to write off bad debts – What a valid credit note entailed.

Supply deemed to be made at time of issue of tax invoice – Deeming provision did not apply where no actual supply made – Purpose of deeming provision to fix time of supply and not to deem supply made when it was not in fact made – Value Added Tax Act 1983, sec. 5(1).

  The issue was whether credit notes issued by the appellant were genuine credit notes or were issued to escape accounting for tax on bad debts, which did not qualify for bad debt relief.

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