Illicitly, against regulations, of goods kept under the serving counter in a shop to be unobtrusively passed to a customer who knows they are available for surreptitious sale (e.g. pornographic magazines in a newsagent).
1969 The Seven Minutes: A Novel[http://books.google.co.uk/books?id=RUo_AAAAIAAJ&q=%22under+the+counter%22&dq=%22under+the+counter%22] - Page 157 by Irving Wallace
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(British, Ireland, colloquial) In an underhand way, sneakily; unofficially, particularly with regard to payment or tax avoidance.
This morning he said he could not remember exactly where or how the invoice was written. It was used to cover up an under the counter payment from the sale of his land in Lucan.
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