In PPG Holdings, the Advocate General opined that a sponsoring employer was not entitled to deduct input VAT incurred on supplies made in connection with the management and operation of a pension fund. The infraction proceedings brought by the Commission against the UK and other Member States in connection with their VAT grouping regimes have been dismissed. In Esporta, the UT held that late paid fees were consideration for the supplies of health club facilities, even where members were denied access to them. In Simpson & Marwick, the Court of Session held that bad debt relief may only be claimed on the VAT fraction of a bad debt, even where the debt is demonstrably all VAT.