Halifax plc v Customs and Excise Comrs

Subject Matter

REVENUE — Tax avoidance — Value added tax — Transaction designed solely for tax avoidance — Whether involving “economic activity” and “supply” — Whether doctrine of abuse of right applicable — Consequence of finding of abusive practice for claim to recovery of input tax — Council Directive 77/388/EEC, arts 2(1), 4, 5(1), 6(1)

(Case C-255/02); EU:C:2006:121; [2006] Ch 387; [2006] 2 WLR 905; [2006] STC 919, ECJ

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