Opinion of the Advocate General — ECLI:EU:C:2001:494
Date: 2001-09-27
Based on: Treaty establishing the European Economic Community (1957)
Subject matter: Taxation;Value added tax
Procedure: Reference for a preliminary ruling
Origin: United Kingdom

Summary of the Judgment 
1. Tax provisions — Harmonisation of laws — Turnover taxes — Common system of 
value added tax — Taxable transactions — Supply of services for consideration — 
Obligations of the supplier not enforceable because of an agreement binding in honour 
only — Taxable 
(Council Directive 77/388, Art. 2(1)) 
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SUMMARY — CASE C-498/99 
2. Tax provisions — Harmonisation of laws — Turnover taxes — Common system of 
value added tax — Taxable amount — Supply of services — Competition whose 
organiser has the entry fees freely at his disposal — Taxable amount consisting of the 
total amount of those fees 
(Council Directive 77/388, Art. 11A(1)(a)) 
1. Article 2(1) of the Sixth Directive 
77/388 on the harmonisation of the 
laws of the Member States relating to 
turnover taxes must be interpreted as 
meaning that a supply of services 
which is effected for consideration but 
is not based on enforceable obligations, 
because it has been agreed that the 
provider is bound in honour only to 
provide the services, constitutes a 
transaction subject to value added tax. 
(see para. 24, operative part 1) 
2. Article 11A(1)(a) of the Sixth Directive 
77/388 on the harmonisation of the 
laws of the Member States relating to 
turnover taxes must be interpreted as 
meaning that the full amount of the 
entry fees received by the organiser of a 
competition constitutes the taxable 
amount for that competition where 
the organiser has that amount freely 
at his disposal. 
(see para. 31, operative part 2) 
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