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When is a Supply Not a Supply?

David Milne QC and Andrew Hitchmough, Pump Court Tax Chambers, discuss the controversial concept of 'non-supply'

 
David Milne QC and Andrew Hitchmough Pump Court Tax Chambers discuss the controversial concept of 'non-supply'
 
A Article 2.1 of the Sixth VAT Directive defines the scope of the charge to VAT.1 It provides that VAT shall be charged on
 
'The supply of goods or services effected for consideration within the territory of the country by a taxable person acting as such'.
 
Although the keystone of the VAT code this is a provision which raises more questions than it answers. For example what is a 'supply' when is a supply 'effected for consideration' what is a 'taxable person' ...

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