Robert Venables QC and Rory Mullan (instructed by Lovells) for LMUK.
Value added tax – Supply of goods or services – Supply – Meaning – Loyalty reward programme – Taxpayer contracting with companies issuing points to customers redeemable for goods and services at participating suppliers – Taxpayer paying service charge including VAT to suppliers for ‘redemption services’ – Whether VAT deductible by taxpayer as input tax – Whether suppliers making supply to taxpayer for VAT purposes – EC Council Directive 77/388, arts 5(1), 6(1).