The Respondent (LMUK) operates the Nectar loyalty card scheme (the scheme). As part of the scheme, it enters into contracts with certain retailers (redeemers). Under such contracts, each redeemer is required to provide customers (collectors) with goods and services wholly or partly in exchange for Nectar points. That they do so is essential to the functioning of the scheme. The collectors earn such points through purchases made from other retailers (sponsors), who pay LMUK for allowing them to do so. Those payments are subject to VAT, on the basis that LMUK provides a taxable supply of services. The Respondent pays each redeemer a service charge for allowing customers to exchange points for goods or services. LMUK sought to deduct the VAT element of the service charge as input tax on the basis that, under the relevant EU legislation, the service charge was paid by LMUK to the redeemers for a service supplied to it for the purpose of its business. The Appellant (the Commissioners) maintained that under that legislation the service charge constituted third party consideration for the redeemers supply of goods and services to collectors, and that therefore LMUK could not deduct input tax. When the issue came before the House of Lords, it referred the question of how to characterise the service charge under EU law to the Court of Justice of the European Union (CJEU). The CJEU concluded that the service charges amounted, at least in part, to third party consideration. When the case returned to the Supreme Court, it nevertheless decided ([2013] UKSC 15) by a majority of three to two that LMUK was entitled to deduct the VAT element of the service charge. It did so on the basis that, having regard to the contractual relationships between LMUK, the sponsors, the collectors and the redeemers, the service charge was paid by LMUK to the redeemers for a service supplied to LMUK for the purpose of its business. The Court respectfully declined to follow the CJEUs characterisation of the service charge as third party consideration on the basis that the terms of the reference to it by the House of Lords had precluded the CJEU from considering all relevant aspects of the relationships between the parties involved in the Nectar scheme. The Court allowed the parties an opportunity to make written submissions as to the form of the order it should make. The Commissioners invited the Court to make a further reference to the CJEU on two principal grounds. First, they argued that a national court is obliged under EU law to make a further reference if it finds the ruling of the CJEU on the first reference to be incomplete or unsatisfactory. Second, they argued that there must be an issue of EU law raised in the present appeal on which a decision is necessary and which cannot be considered to be reasonably clear, as the Supreme Court decided the case by a narrow majority. LMUK opposed a further reference and invited the Court to dismiss the appeal. The Supreme Court unanimously refuses the Commissioners request for a further reference to the CJEU and dismisses the appeal. Lord Reed gives the judgment of the Court. The Court rejects the Commissioners first principal argument [4 5]. It notes that its previous judgment had not questioned the CJEUs ruling on any question of EU law, but rather had proceeded on the basis of a more comprehensive account of the facts than the CJEU was afforded. The Courts previous judgment had, first, considered that the CJEUs judgment had identified the relevant principles of law but had applied them to the incomplete factual scenario it had been presented with by the House of Lords and, second, applied those principles to the fuller factual account of which it was apprised. As such, no question of EU law now arises and a further reference is not necessary. The Court also rejects the Commissioners second principal argument [6]. It does so on the basis that, in the Courts previous judgment, the majority considered that the case could be decided by applying well established principles to the facts of the case. Further, the majority and the minority both acknowledged that the CJEU judgment dealt with the case on the basis that it raised no new point of law. The issues raised by the minority in the previous judgment, so far as relating to EU law, are not considered to require or justify a further reference to the CJEU. As a result of the above findings, the Court does not consider a further reference to the CJEU to be necessary. It also notes that it would be unfortunate if the position were otherwise, given that this litigation commenced in 2003 [7].