No. 18,236

Decision given on 17 July 2003 by Mr Sadler (Chairman).

Bad debt relief – Conditional sale agreement – Allocation of instalment payments between goods and credit charge – Whether allocation made by terms of agreement – Whether allocation to be made in accordance with taxpayers’ accounting treatment – Whether statutory method of apportionment contrary to Community law – Directive 77/388, the sixth VAT directive, art. 11(C)(1); Value Added Tax Act 1994, s. 36; Value Added Tax Regulations 1995 (SI 1995/2518), reg. 170 and 170A.

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