Single composite supplies vs multiple supplies

Where a supply comprises a number of different elements with varying VAT treatments, the question arises as to whether each element of the supply should be treated individually for VAT purposes (a multiple or mixed supply) or whether all of the elements of the supply should assume the same VAT treatment (a single or composite supply) and, if so, which treatment.

This question has consistently troubled the courts, HMRC and taxpayers, and has regularly been considered by both the domestic courts and the EU Court of Justice. This Practice Note considers the current state of the law and practice in this area.

The UK ceased to be an EU Member State on 31 January 2020, and the implementation period, during which the UK continued to be treated as a Member State for many purposes, ended at 11pm on 31 December 2020. For information on the ongoing significance of EU Directives, and of judgments of the Court of Justice, for the UK’s VAT rules,