VAT on composite supplies
Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP
VAT on composite supplies

The following Tax practice note produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP provides comprehensive and up to date legal information covering:

  • VAT on composite supplies
  • Single composite supplies vs multiple supplies
  • Why the need to distinguish between single and multiple supplies?
  • Question of law or fact?
  • Tour operators
  • What test is applied?
  • Ancillary supplies
  • Single indivisible economic supply
  • Earlier case law
  • Nature of the single supply
  • More...

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, see Practice Note: Brexit and tax—the continued application of EU law.

Why the need to distinguish between single and multiple supplies?

In the UK, a transaction may, generally speaking, be:

  1. subject to VAT at the standard rate or reduced rate (for further details, see Practice Notes: When does VAT apply? and VAT—zero-rated and reduced rate supplies)

  2. exempt (for further details,

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