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Paragon Customer Communications v HMRC

Supply of services or goods?

In Paragon Customer Communications v HMRC [2018] UKFTT 162 (28 March 2018) the FTT found that an information booklet on the terms of a specific individual’s policy supplied to an insurance company qualified for zero-rating under VATA 1994 Sch 8 Group 3.

Paragon ‘plans creates and delivers’ printed and digital communications. The main issue was whether multiple sheets of information about an individual’s insurance policy stapled together and bound in covers which it supplied to Direct Line Insurance were zero-rated.

The FTT referred to Secret Hotels2 [2014] UKSC 16 (inter alia) as authority for the proposition that the contractual terms are a good starting point to ascertain what is actually supplied. The FTT therefore analysed the contents of the statement of work (entered into under a framework agreement) relating to the relevant printed items. The FTT observed that the...

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