SUPPLY OF THE NEW GOODS OBTAINED BY THE SUPPLIER FROM THE PURCHASER . THAT VALUE THEREFORE FORMS PART OF THE TAXABLE AMOUNT OF THE GOODS , IN ACCORDANCE WITH ARTICLE 11 OF THE SIXTH DIRECTIVE . ACCORDING TO THE COMMISSION , ARTICLE 32 REFERS TO SPECIAL SYSTEMS APPLICABLE TO SECOND-HAND GOODS AND CERTAINLY DOES NOT PERMIT ANY DEROGATION FROM THE RULES RELATING TO THE TAXABLE AMOUNT OF NEW GOODS . FURTHERMORE , NONE OF THE PROPOSALS MADE BY THE COMMISSION WITH A VIEW TO ESTABLISHING A COMMON SYSTEM FOR THE TAXATION OF SECOND-HAND GOODS PERMITS A DEROGATION OF THAT KIND . UNLIKE THOSE PROPOSALS , THE IRISH SYSTEM DOES NOT BENEFIT THE ULTIMATE PURCHASER OF THE SECOND-HAND GOODS SO MUCH AS THE PURCHASER OF THE NEW GOODS , WHO IS THEREBY DIRECTLY ACCORDED A REDUCTION IN VAT .
5 ACCORDING TO THE COMMISSION , THE IRISH PROVISION AT ISSUE CANNOT BE REGARDED AS A SPECIAL SYSTEM WHICH PREVENTS SECOND-HAND GOODS FROM BEING TAXED TWICE , IN ACCORDANCE WITH THE OBJECTIVES OF ARTICLE 32 OF THE SIXTH DIRECTIVE . IT DOES NOT APPLY TO THE WHOLE SECOND-HAND MARKET , BUT SOLELY TO CASES IN WHICH SECOND-HAND GOODS ARE TRADED IN ON THE OCCASION OF THE SUPPLY OF OTHER GOODS . THAT SITUATION IS DEALT WITH IN ARTICLE 11 OF THE SIXTH DIRECTIVE AND CANNOT AT THE SAME TIME BE GOVERNED BY A SPECIAL SYSTEM WITHIN THE MEANING OF ARTICLE 32 .
6 LASTLY THE COMMISSION POINTS OUT THAT THE IRISH SYSTEM RESULTS IN A LOSS OF REVENUE FOR THE EXCHEQUER AND THUS A DIMINUTION OF THE COMMUNITIES ' S OWN RESOURCES WHERE THE RESALE PRICE OF THE SECOND-HAND GOODS IS LOWER THAN THE TRADE-IN PRICE .
7 IRELAND EXPLAINS THAT THE SALE OF NEW GOODS INVOLVING A TRADE-IN OF SECOND-HAND GOODS IS BY FAR THE MOST COMMON WAY IN WHICH USED GOODS OF CERTAIN KINDS , PARTICULARLY MOTOR CARS , RE-ENTER COMMERCIAL CIRCULATION IN IRELAND . THE IRISH PROVISION AT ISSUE THUS REGULATES THE MAJOR PART OF TRADE IN SECOND-HAND GOODS AND ENABLES THAT PART OF THE MARKET TO AVOID THE DOUBLE TAXATION TO WHICH SECOND-HAND GOODS WOULD OTHERWISE BE LIABLE IN VIEW OF THEIR LIABILITY TO VAT ON RESALE . IT IS INDEED , THEREFORE , A SPECIAL SYSTEM WITHIN THE MEANING OF ARTICLE 32 OF THE SIXTH DIRECTIVE . ALTHOUGH IT IS TRUE THAT THAT SYSTEM APPLIES IN THE CASE OF A SUPPLY WHICH IS SUBJECT TO THE RULES SET OUT IN ARTICLE 11 OF THAT DIRECTIVE , THAT IS BECAUSE THE SUPPLY OF GOODS BY THE TAXABLE PERSON IS INSEPARABLE FROM THE SIMULTANEOUS ACQUISITION BY HIM OF THE USED GOODS TRADED IN . IF THE DEDUCTION PERMITTED IN SUCH A CASE BY THE CONTESTED PROVISION WERE NOT AUTHORIZED BY COMMUNITY LAW , A TAXABLE DEALER WOULD NOT BE ABLE TO DEAL IN USED MOTOR CARS BELONGING TO NON-TAXABLE CUSTOMERS EXCEPT AT A LOSS .
8 ACCORDING TO IRELAND , THE INTERPRETATION OF ARTICLE 32 OF THE SIXTH DIRECTIVE