Value added tax – Input tax. The Upper Tribunal (Tax and Chancery Chamber) had found that the taxpayer was not entitled to deduct input tax from the fees that it had paid under a tri-partite agreement because it had not been the recipient of the supply of services for the purposes of s 24 of the Value Added Tax Act 1994. The Court of Appeal, Civil Division, upheld that decision as the tribunal had asked itself the correct question and had reached sustainable conclusions on its assessment of the relevant agreement.