[2013] CSIH 29.

Lord Eassie.

Opinion delivered 12 April 2013.

Value added tax – Bad debt relief – VAT-only invoices – Taxpayer solicitors acting for insurance companies – Insurers paying fees excluding VAT – VAT-only invoices issued to VAT-registered insureds – VAT-only invoices unpaid by insureds – Whether bad debt relief limited to VAT proportion of invoices – Whether restriction disproportionate interference with right to enjoyment of possessions – Directive 77/388, art. 11(C)(1) – Value Added Tax Act 1994, s. 36 – European Convention on Human Rights, Protocol 1, art. 1 – Human Rights Act 1998, s. 3.

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