49That conclusion is, moreover, endorsed by the explanatory memorandum to the proposal for the Sixth Directive (Bulletin of the European Communities, supplement 11/73, p. 13) in which the Commission observes that ‘when payments on account are received prior to the chargeable event, receipt of these amounts gives rise to a charge to tax, since the parties to the transaction in this way demonstrate their intention that all the financial consequences of the chargeable event should arise in advance’.
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