Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

Allow the VAT!

26 November 2007
Categories: Tax cases
CRC v Loyalty Management UK Ltd, Court of Appeal, 5 October 2007

Loyalty Management UK Ltd which runs the Nectar customer loyalty rewards programme entered into various agreements with retailers customers and suppliers. Under the retailers agreement the retailer helped in the issue of points with customers and paid to the taxpayer a specified sum in respect of each point issued and a marketing fee. The agreement with customers was that they received points when they purchased 'primary' goods from the stated retailers and they could use those points to acquire 'secondary' points from other suppliers. It was agreed with the suppliers that if they provided goods to customers in return for points the taxpayer would pay them a reward fee i.e. an agreed value for the points.

The taxpayer claimed the VAT on the reward fee. HMRC did not allow the claim. The VAT tribunal allowed the taxpayer's appeal but the High...

If you or your firm subscribes to, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.

back to top icon