V3.106 Multiple supplies

General

A multiple, or mixed, supply has been defined as a single transaction involving the supply of a number of separable goods or services. Each supply must be considered as an independent supply for tax purposes, the single consideration being apportioned as appropriate1. For the principles utilised by the courts in distinguishing multiple supplies from composite supplies, see V3.105.

Clearly a taxpayer whose customers (direct or otherwise) are unable fully to recover any tax charged to them is likely to argue that he is making a single supply where the amount of tax on that supply is less than it would be were the transaction(s) to be regarded as multiple supplies. For example, a food manufacturer might argue that he is making a single zero-rated supply of food, rather than multiple supplies of zero-rated food and standard-rated packaging2. On the other hand, he is likely to argue that he is making a multiple supply where the amount of tax on that supply is less than it would be were the transaction(s) to be regarded as a single supply (eg he is making multiple supplies of zero-rated printed matter and standard-rated advertising services, rather than a single supply of standard-rated promotional services)3. Alternatively he might wish to argue that he is making multiple supplies (taxable and exempt), rather than (a) a single taxable supply, or (b) a single exempt supply in order to decrease the amount of output tax payable (in the case of (a)), or increase the amount

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