Marriott Rewards and another v HMRC

Cathya Djanogly

In Marriott Rewards and another v HMRC [2017] UKFTT 140 (27 January 2017) the FTT found that a reward scheme operated by Marriott hotels did not involve third party consideration but dismissed the appeals on the ground that VAT was still due (or not recoverable) as a result of the application of the pre-January 2010 place of supply rules.

The appeal concerned the customer loyalty scheme relating to hotels operated under the ‘Marriott’ brand. The scheme was run by Marriott Rewards (MR).

Whenever a customer who was a member of the programme purchased a qualifying stay at a participating hotel MR issued reward points to the member and charged the hotel for doing so. When a member had earned enough reward points he was able to use those points to obtain a free stay at a participating hotel. MR then made a payment to the hotel...

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