“one must first consider the effect of the contractual documentation, and then see whether any conclusion is vitiated by the facts relied on by either party. ”
“ ‘ the travel agent’s contractual obligations towards the traveller ’ are of particular importance in deciding whether [the relevant European law] applies but it is also necessary to ‘ hav[e] regard to all the details of the case ’ , and, in that connection, the ‘ economic and commercial realities ’ represent ‘ a fundamental criterion ’ . A contract which does not reflect ‘ economic reality ’ and a ‘ purely artificial arrangement ’ are similar to the shams, rectifiable agreements and other arrangements considered in para 33 above.” 132. At [57] he decided that economic reality did not in that case assist a contrary view to that based on his analysis of the contractual position noting that: “ one must be careful before stigmatising the contractual documentation as being ‘ artificial ’ , bearing in mind that EU law, like English law, treats parties as free to arrange or structure their relationship so as to maximise its commercial attraction, including the incidence of taxation – see RBS Deutschland …”
“ ‘ consideration of economic realities is a fundamental criterion for the application of the common system of VAT ’ , and added that that issue involved consideration of ‘ the nature of the transactions carried out ’ in the particular case.” 137. He continued, at [49], to cite comments from other CJEU cases as being much to the same effect such as the CJEU’s comments in Newey that a supply of services is effected for consideration only if there is a legal relationship between the provider of the service and the recipient pursuant to which there is reciprocal performance, which the CJEU explained as meaning “the remuneration received by the provider of the service constituting the value actually given in return for the service supplied to the recipient”
“In our view the correct approach is clear from Newey and Secret Hotels2 . The test is an objective one (see also on that Commission v Finland (Case C-246/08 )[2009] ECR I-10605 at [37]). The contractual terms must be considered. It is also necessary to consider the ‘ economic and commercial reality ’. If the terms reflect the economic and commercial reality then it is not necessary to go any further.”
“Where goods or services are supplied for a consideration in money, which is to be reduced if payment is made immediately or within a specified time, the consideration shall be taken for the purposes of this part of this Act as so reduced whether or not payment is so made.” (2) Article 79 PVD states that the taxable amount shall not include not only price reductions by way of discount for early payment, but also “price discounts and rebates granted to the customer and obtained by him at the time of supply .” (3) On the plain meaning and certainly without resorting to any muscular interpretation the term “prompt” is more than able to cover “immediate” or “early”
“ is authority for a highly muscular approach to the construction of national legislation so as to bring it into conformity with the directly effective Treaty obligations of the United Kingdom.” 206. HMRC noted that this approach applies whether the EU law point is taken by the taxpayer or HMRC referring to HMRC v IDT Card Services[2006] EWCA Civ 29 ,[2006] STC 1252 . In HMRC’s view, the correct approach is set out in that case and in Swift (trading as A Swift Move) v Robertson[2014] UKSC 50 ,[2014] 1 WLR 2438 at [20]-[22] (Lord Kerr). (The relevant comments in these decisions are set out in the decision section.) 207. In HMRC’s view, on the muscular approach advocated in these authorities, para 4(1) can be interpreted in accordance with the PVD as only applying to reduce the consideration for the supply of FLR services to the extent that the “discounted” saver price was actually paid. That was the approach adopted in the Saga Holiday Ltd case and the same approach should be followed by the tribunal in this case. Details of the Saga case are set out in the decision section below. 208. HMRC accepted that if para 4(1) cannot be interpreted to conform in full with the PVD, and it is held that para 4(1) entitles a taxpayer to account for VAT based on an amount less than it had in fact received, then (subject to para 4(2)), the taxpayer can rely on that entitlement notwithstanding the correct position under EU law. 209. In HMRC’s view, when the PPD legislation was changed in 2014, there was a clear recognition that the previous version of para 4(1) in dispute here could be interpreted as being in line with the PVD but, because of the degree of ambiguity, it was amended to provide clarity. This was not, as VML asserted, a narrowing of the previous scope of para 4(1). The explanatory memorandum published with the draft legislation in 2014 stated that the PVD requires VAT to be accounted for on the consideration actually received and noted that whilst “UK legislation may be interpreted as being in line with the PVD” it “has a degree of ambiguity, so is being amended to provide clarity on the VAT treatment of prompt payment discounts.”
“……In summary, the obligation on the English courts to construe domestic legislation consistently with Community law obligations is both broad and far-reaching. In particular: (a) it is not constrained by conventional rules of construction (per Lord Oliver of Aylmerton in the Pickstone case, at p 126B); (b) it does not require ambiguity in the legislative language (per Lord Oliver in the Pickstone case, at p 126B and per Lord Nicholls of Birkenhead in Ghaidan's case, at para 32); (c) it is not an exercise in semantics or linguistics (per Lord Nicholls in Ghaidan's case, at paras 31 and 35; per Lord Steyn, at paras 48—49; per Lord Rodger of Earlsferry, at paras 110—115); (d) it permits departure from the strict and literal application of the words which the legislature has elected to use (per Lord Oliver in the Litster case, at p 577A; per Lord Nicholls in Ghaidan’s case, at para 31); (e) it permits the implication of words necessary to comply with Community law obligations ( per Lord Templeman in the Pickstone case, at pp 120H—121A; per Lord Oliver in the Litster case, at p 577A); and (f) the precise form of the words to be implied does not matter (per Lord Keith of Kinkel in the Pickstone case, at p 112D; per Lord Rodger in Ghaidan’s case, at para 122; per Arden LJ in the IDT Card Services case, at para 114)….. ….The only constraints on the broad and far-reaching nature of the interpretative obligation are that: (a) the meaning should go with the grain of the legislation and be compatible with the underlying thrust of the legislation being construed: see per Lord Nicholls in Ghaidan v Godin-Mendoza[2004] 2 AC 557 , para 33; Dyson LJ in Revenue and Customs Comrs v EB Central Services Ltd[2008] STC 2209 , para 81 …” 221. HMRC argued that, as regards para 4(1) the conforming construction to be adopted in this case is that set out by the tribunal in the Saga case. In that case Saga claimed that it had overpaid VAT on its takings on supplies of holiday services, as it had accounted for tax on the full price, without taking account of discounts offered for early payment. HMRC accepted that tax was overpaid in cases where the appellant’s customers actually received discounts but not where discounts were available but were not taken up. 222. The tribunal set out at [30] to [32] the history of para 4(1) and the relevant wording in the European provisions and concluded that para 4(1) was clearly intended to enact the equivalent of article 79 relating to discounts for early payment. At [33], the tribunal noted that para 4(1) could be more clearly worded but concluded that the better interpretation is that the PPD regime applies to reduce the consideration for VAT purposes only where a discount is in fact achieved. The tribunal formed this view by ignoring, at this stage of the analysis, the final words of para 4(1) “whether or not payment is made in accordance with those terms” : “ The reference to terms “allowing” a discount does open up the possibility of reading the provision as applying where, although the terms allowed for it, the discount had not been achieved. The possibility of so reading it is diminished by the next phrase “the consideration shall be taken … as reduced by the discount ”
“Whether or not payment is made in accordance with those terms” could suggest that it is the existence of the right to a discount that gives rise to the reduced consideration for VAT purposes. However, if the earlier words mean that the discount has to be achieved before it can affect the consideration, as we have held they do, the last words in the paragraph can be taken to apply to the situation where the discount is in fact allowed, even though on the strict terms agreed between the parties it could have been refused. We do not therefore hold that the closing words contradict the interpretation that we have put on the opening words.”