Dixons Carphone v HMRC

In Dixons Carphone v HMRC [2018] UKFTT 557 (25 September 2018) the FTT found that the provision of a loan by a third party as part of credit arrangements for the purchase of consumer goods did not amount to third party consideration.

Dixons sells electronic goods in its stores. The transactions at issue took place as follows. A consumer would purchase goods in a Dixons store and pay a deposit; the balance was funded by a loan from a third party LaSer. The customer gave authority to LaSer to pay the money borrowed to Dixons. Where the loan was on favourable terms to the customer the amount paid by LaSer to Dixons was a lower amount than that authorised by the consumer following deduction of an amount described as a subsidy. The favourable terms were generally interest free arrangements...