Court of Session (Inner House).

The Lord President (Lord Rodger of Earlsferry), Lord Caplan and Lord Weir.

Judgment delivered 18 March 1998.

Value added tax – Exemption – Finance – Personal equity plan – Initial charge to invest in managed portfolio – Whether charge for making of arrangement for the issue, transfer or receipt of, or dealing with any security – Value Added Tax Act 1994, Sch. 9, Grp. 5, item 6(a), 7; Directive 77/388 of 17 May 1977, (OJ 1977 L145), art. 13(B)(d)5.

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