15-670 Principles arising from caselaw on single or multiple supply
The tribunals and courts have considered many claims that a transaction amounted to a single supply or a multiple supply. Although there are many cases, the issue can still be unclear in many situations.
Sometimes the taxpayer and HMRC agree on much of the facts and the law. Only the outcome is disputed as the arguments of both parties seem equally strong.
The dispute with HMRC often concerns output tax but may concern input tax because input tax can be reclaimed on costs that relate to zero-rated sales, but not those that are exempt.
Principles arising from cases
The following principles arise from the cases in deciding whether there was a single or a multiple supply: