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- Strict interpretation does not apply to place of supply rules 

 

"[32] Before addressing the grounds of appeal it is important to recognise, as Mr Milne emphasised, that like the corresponding provision in the Sixth Directive, article 59(c) of the Principal VAT Directive is not an exemption that must be strictly construed." (HMRC v. Gray & Farrar International LLP [2023] EWCA Civ 121, Simler LJ)

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 © 2025 by Michael Firth KC, Gray's Inn Tax Chambers

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