In Astra Zeneca UK Ltd v HMRC (ECJ Case C-40/09) a pharmaceutical company gave its employees face-value vouchers as part of their remuneration. HMRC issued a ruling that this was a supply of services for consideration which was subject to VAT. The company appealed contending that it was not making any supply of services but that it should be allowed an input tax deduction on the costs of purchasing and providing the vouchers.
The tribunal referred the case to the ECJ which rejected the company’s contentions holding that Article 2(1) of the Sixth Directive ‘must be interpreted as meaning that the provision of a retail voucher by a company which acquired that voucher at a price including value added tax to its employees in exchange for their giving up part of their cash remuneration...
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In Astra Zeneca UK Ltd v HMRC (ECJ Case C-40/09) a pharmaceutical company gave its employees face-value vouchers as part of their remuneration. HMRC issued a ruling that this was a supply of services for consideration which was subject to VAT. The company appealed contending that it was not making any supply of services but that it should be allowed an input tax deduction on the costs of purchasing and providing the vouchers.
The tribunal referred the case to the ECJ which rejected the company’s contentions holding that Article 2(1) of the Sixth Directive ‘must be interpreted as meaning that the provision of a retail voucher by a company which acquired that voucher at a price including value added tax to its employees in exchange for their giving up part of their cash remuneration...
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