Queen’s Bench Division (Crown Office List).

Carnwath J.

Judgment delivered 30 January 1998.

Value added tax – Partial exemption – Attribution of input tax – Advertising services supplied outside the UK – Predominantly exempt supplies later made in UK – Whether direct attribution of input tax to overseas supplies permissible – Value Added Tax (General) Regulations 1985 (SI 1985/886), reg. 30 and 32 (Value Added Tax Regulations 1995, (SI 1995/2518), reg. 101 and 103); Sixth VAT directive (Directive 77/388) of 17 May 1977 (OJ 1977 L145/1), art. 17 and 19.

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