Consideration is not defined in UK or EU law, but the courts have noted cases based on former Directive 67/228 (‘the second directive’), Annex A, para. 13. It defined consideration as ‘everything received in return for the supply of goods or the provision of services, including incidental expenses (packing, transport, insurance, etc.): that is to say not only the cash amounts charged but includes the value of the goods received in exchange or, in the case of goods or services supplied by order of a public authority, the amount of the compensation received’ (C & E Commrs v Littlewoods Organisation plc  BVC 71, at p. 75E).
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