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Ratio decidendi: Lower courts were wrong in deciding that such transfer of property would be exempt from vAt similarly to the repayment of money under loan. transfer of property by virtue of accord and satisfaction agreement for the purpose of cancelling obligations under loan contract is in legal terms the sale of a property, in which case the transferring party must pay output vAt from such sale, whereas the receiving one may offset input vAt.

Ratio Decidendi of Select Decisions of Russian Highest Courts