VAT

The appropriate test to determine whether there was a supply of services to a taxable person for the purposes of s 24(1) of the Value Added Tax Act 1994, as laid down in Customs and Excise Commissioners v Redrow [1999] 2 All ER 1, [1999] STC 161 was to ask whether something was “being done for him [the taxable person] for which, in the course or furtherance of a business carried on by him, he has had to pay a consideration which has attracted value added tax”. In the light of other authorities (Revenue and Customs Comrs v Aimia Coalition Loyalty UK Ltd [2013] UKSC 15, [2013] 2 All ER 719; WHA Ltd v Revenue and Customs [2013] UKSC 24, [2013] 2 All ER 907; and Revenue and Customs Comrs v Loyalty Management UK Ltd: C-53/09 and C-55/09 [2010] STC 2651, [2010] All ER (D) 98 (Oct)), there had been a refinement, or gloss applied, to