V16.868 Single or multiple supplies—how to decide
Vat Information Sheet 2/01 July 2001
1 Business Brief 2/01, issued on 16 February 2001, explained the European Court of Justice (ECJ) and the House of Lords decisions in the case of Card Protection Plan (CPP) (BB/12B/01, Division V16.3). These decisions affect the way in which businesses are required to decide whether they are making single or multiple supplies for VAT purposes.
What are single and multiple supplies and what is the effect on VAT?
2 Ever since the start of VAT there have been problems in deciding the proper VAT liability of supplies consisting of separately identifiable goods or services. This is particularly relevant where some elements are taxable and others which, if supplied on their own, would qualify for relief from VAT.
3 A typical example of this is a taxable supply of tuition that includes the provision of books which, on their own, would be zero-rated. The question is, therefore, can the books be treated separately from the tuition for VAT purposes or are they properly part of an overall standard-rated supply of tuition? There are many other situations where the same problem arises—for example, the standard-rated supply of hiring cars with exempt insurance and the supply of standard-rated catering to passengers on board zero-rated forms of transport.
4 Neither UK nor European VAT legislation provides rules for deciding these questions. Over the years, however, many cases have been heard by the VAT Tribunal and UK courts and these precedent cases have produced general guidelines