Decision given on 25 July 2005 by Mr Hellier (Chairman).
Supply for consideration – Whether foreign exchange transactions always constitute such supplies by both parties – Whether a counterparty's profit from foreign exchange transactions is consideration for its supply – Value Added Tax Act 1994, s. 5(2); EC Directive 77/388, the Sixth Directive, art. 2 and 11.
The central issue was the meaning and effect of the judgment in First National Bank of Chicago v C & E Commrs (C-172/96)  BVC 389 that foreign currency transactions constitute supplies of services effected for consideration within the meaning of art. 2(1) of the Sixth Directive.