House of Lords.

Lord Browne-Wilkinson, Lord Lloyd of Berwick, Lord Nolan, Lord Hoffmann and Lord Clyde.

Judgment delivered 18 June 1998.

Value added tax – Supply of goods – VAT avoidance scheme – Supplies between company group members – Time of supply – Supplies within group ‘disregarded’ – Part payment made for goods to be supplied within group followed by supplier leaving group before delivery of goods – Whether supply treated as taking place when part payment made – Value Added Tax Act 1983, s. 5(1), 29 (Value Added Tax Act 1994, s. 6(4), 43).

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