Single or multiple supplies ― relevant case law

By Tolley

The following Value Added Tax guidance note by Tolley provides comprehensive and up to date tax information covering:

  • Single or multiple supplies ― relevant case law
  • Single supplies
  • Multiple supply
  • Anti-Avoidance ― supply splitting

This guidance note provides an overview of relevant case law that may be of assistance to a business or its adviser in determining whether the business is making a single or multiple supply for VAT purposes. This note should be read in conjunction with the Single or multiple supplies ― application of Card Protection Plan and Levob Verzekeringen guidance note.

All links to cases are subscription sensitive.

Single supplies

In the following cases the courts held that the supplier was making a single supply for VAT purposes.

Mander Laundries

This was one of the first cases decided on this particular matter and it should be noted that the VAT treatment of some of the items supplied has changed since this decision was reached.

Mander Laundries v The Commissioners [1973] VATTR 136 (BIRM/73/31)

In this case the trader argued the launderette made multiple supplies of mixed liabilities, namely, use of a washing machine and salt used for softening water which was a standard-rated supply. Oil or gas used for heating and the supply of electricity were zero-rated.

The tribunal concluded there was a single supply, which was the licence to use the washing machine to clean clothes. The tribunal stated that the customer goes to the launderette to wash dirty clothes in a washing machine. What is obtained at the end of the transaction is clean clothes and that this is the provision of a service of which the water, gas and electricity form an integral part. The electricity, gas and water were in fact supplied to the launderette and the launderette was not selling these components to the customer but enabling the customer to use these supplies in order to wash their clothes.

British Airways

British Airways (BA) supplied zero-rated flights for a single price

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