Supply – Whether taxable or exempt – Fuel cards – Whether appellent supplied goods or services to its customers or whether the goods or services were supplied by the merchant to the customers with the cards used to make payment – Extent to which substance and reality of operation of agreement, and not merely form of agreement, governed VAT position– Value Added Tax Act 1983, s. 3(2), 4(2) and 17(1); Sch. 6, Grp. 5, items 1, 2 and 5 and Note (4).
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