This guidance note looks at the other issues that need to be considered when determining whether a single or multiple supply is being made. This guidance note should be read in conjunction with the Single or multiple supplies ― overview, Single or multiple supplies ― indicators that it is a single or multiple supply and Multiple supplies ― output tax apportionment guidance notes.
Normally, if a single supply is being made then it can only have one VAT liability applied to it; however, there are limited exceptions to this rule where UK legislation has restricted the scope of the zero rate, reduced rate or exemption.
The CJEU judgment in Talacre Beach Caravan Sales Ltd provides an example of a situation where this has occurred.
This case confirmed HMRC’s view that a single composite zero-rated supply that included a component which was specifically blocked by the legislation from being zero-rated must be apportioned between the zero-rated and standard-rated items. It is not possible
Foreign tax reliefIncome and gains may be taxable in more than one country. The UK has three ways of ensuring that the individual does not bear a double burden:1)treaty tax relief may reduce or eliminate the double tax2)if there is no treaty, the individual can claim ‘unilateral’ relief by deducting
Subsistence expensesIntroductionSubsistence is the amount incurred as a consequence of business travel. Typically it relates to accommodation and meal costs incurred. These amounts are allowed because they are associated with the necessary travel which is not to a permanent workplace. See the Travel
Overseas property businesses for companiesOverviewReal estate income is generally taxed where the property is located; the UK tax treaties generally allow the jurisdiction where the land is located to tax income from the land.Therefore, a UK company with overseas property may be subject to tax in