[2011] UKPC 40.

Lord Phillips, Lord Brown, Lord Mance, Lord Wilson, Sir Stephen Sedley.

Judgment delivered 25 October 2011.

Value added tax – Income tax – Supply of services – Trading receipts – Deposit – Taxpayer supplying bottled and tanked gas to customers in Mauritius – Deposits paid in respect of containers which remained property of taxpayer – Whether taxpayer liable to VAT on retained deposits – Whether taxpayer liable to income tax on deposits as trading receipts – Taxpayer’s appeal allowed.

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