[2017] UKSC 26

Lord Neuberger, President, Lord Kerr, Lord Reed, Lord Carnwath, Lord Gill (Scotland)

Judgment delivered 5 April 2017

Value added tax – Partial exemption special method (PESM) – Hire purchase (HP) transactions – Supplies of both motor vehicles (taxable) and credit (exempt) – (1) Whether residual cost inputs had direct and immediate link with, and cost components of, taxable supplies of motor vehicles – (2) Whether PESM, which attributed 50% of the residual input costs to taxable outputs, was fair and reasonable – HMRCʼs appeal dismissed – Directive 2006/112,art. 173 – Value Added Tax Regulations 1995 (SI 1995/2518), reg. 102.

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