Between 1 January and 30 April 2014, the telecomms provider offered its customers the option of receiving a 15% discount on services if their monthly bills were paid within 24 hours.

TalkTalk accounted for VAT on the basis that the consideration received for VAT purposes was reduced by the discount, whether or not customers had in fact paid through the scheme, which was called the Speedy Payment Discount (SPD) scheme.

On 9 February 2015, HMRC decided that the SPD offer only reduced the consideration for VAT purposes where customers had paid the reduced amount and that there was no reduction when the discount was not taken up.