VAT

In accordance with Art 2 of the Sixth Directive, which defined the scope of VAT, “the supply of…services effected for consideration” was subject to VAT and that, in accordance with the Court’s settled case-law, a supply of services was effected “for consideration”, within the meaning of Art 2(1) of the Sixth Directive, only if there was a legal relationship between the provider of the service and the recipient pursuant to which there was reciprocal performance, the remuneration received by the provider of the service constituting the value actually given in return for the service supplied to the recipient. Further, the court had held that subsidies directly linked to the prix of a taxable transaction were only one situation amongst others referred to in Art 11A(1)(a) of the Sixth Directive and that, irrespective of the particular situation in question, the taxable amount in respect of a supply of services was everything which made up the consideration for the service. Since Art