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The principle of fiscal neutrality is not, in practice, a single principle, but two or more related, but distinct ones. No complete definition of the principle has ever, it appears, been attempted; Lindsay J got closer than most when he said¹:

'The ECJ does little to help by failing to refer to some locus classicus as to that principle. I may be alone in finding references to it as varying in emphasis depending upon its context; sometimes it seems to direct one to the way in which VAT is intended to be passed on, by way of deductibility, supplier to supplier, until it is finally and irrecoverably borne by the ultimate consumer-recipient. Another aspect of the principle is that a person who, within the EU, provides services which are exempt for VAT purposes cannot recover the input tax attributable to those services – see WHA Ltd & another v Revenue and Customs Commissioners [2007] STC 1695 at para 16. Sometimes the principle seems to refer to a sort of fiscal parity, as between