Court of Session (Inner House).

Lord Justice-Clerk Gill, Lord Coulsfield and Lord Sutherland.

Judgment delivered 26 February 2002.

Value added tax – Exemption – Zero-rate – Taxpayer issued own bank notes – Agreement between banks to use one another’s ATMs – Reciprocity fee paid when one bank’s customers used another’s ATMs – Whether dispensing of taxpayer’s banknotes transposed exempt supply into zero-rated supply – Value Added Tax Act 1994, Sch. 8, Grp. 11, item 1, Sch. 9, Grp. 5, item 1.

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