Kuwait Petroleum (GB) Ltd v Customs & Excise [2001] EWCA Civ 337 (9 March 2001)

Kuwait Petroleum (GB) Ltd v Customs & Excise [2001] EWCA Civ 337 (9 March 2001)

There is a more than fanciful prospect of success in the argument that the provision of redemption goods may be treated as a post-supply price reduction rather than a supply for consideration, warranting permission to appeal.

Citation
[2001] EWCA Civ 337
Parties
Appellant/applicant: Kuwait Petroleum (GB) Limited; Respondent/respondent: The Commissioners of Customs and Excise
Jurisdiction
England and Wales
Judgment Date
09 March 2001
Procedural Posture
Civil Appeal / Renewed Application for Permission to Appeal
Outcome
permission to appeal granted
Legal Topics
VAT, Customer Loyalty Programmes, Principle of Neutrality, EC Sixth Directive

Case Brief

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Parties

Kuwait Petroleum (GB) Limited

Appellant/applicant

The Commissioners of Customs and Excise

Respondent/respondent

Procedural Posture

Civil Appeal / Renewed Application for Permission to Appeal

  1. 1 Whether the provision of redemption goods under a customer loyalty programme constitutes a post-supply price reduction for VAT purposes under Article 11C of the Sixth Directive
  2. 2 Whether such provision breaches the principle of neutrality in VAT law

Ratio Decidendi

There is a more than fanciful prospect of success in the argument that the provision of redemption goods may be treated as a post-supply price reduction rather than a supply for consideration, warranting permission to appeal.

Court Disposition

permission to appeal granted

Orders

  • Permission to appeal granted to the appellant
  • Appellant permitted to file a further skeleton argument