Value added tax – Tax avoidance scheme. The Supreme Court allowed an appeal by the Revenue and Customs Commissioners against the decision of the Court of Appeal, Civil Division, which had decided that the scheme at issue in the present proceedings used by the taxpayer Pendragon group, designed to exploit exceptions to the normal incidence of VAT, was not an abuse of law as defined in Halifax plc v Customs and Excise Comrs: C-255/02 [2006] STC 919 (Halifax). The Court decided that the two requirements laid down in Halifax had been satisfied with the result that the scheme had been an abuse of law.