Marriott Rewards LLC and Whitbread Group PLC v The Commissioners for HM Revenue and Customs: [2018] UKUT 0129 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Henry Carr and Judge Ghosh on 30 April 2018.

• From: HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
• Published: 30 April 2018

• Category: Tax
• Release date: 30 April 2018

Read the full decision in Marriott Rewards LLC and Whitbread Group PLC v The Commissioners for HM Revenue and Customs: [2018] UKUT 0129 (TCC) .

VALUE ADDED TAX – “points” based rewards scheme – whether payments made to redeemers third party consideration for supply of rewards – no – whether redeemers made separate supplies to operator of scheme – yes – whether those separate supplies relate to immovable property or constitute advertising services – no – appeals dismissed.

Published 30 April 2018