alivery services were ancillary to an exempt supply of stabling; and
bthere was a single, exempt supply.
HMRC's practice is in Business Brief 21/2001 (21 December 2001), which is reproduced below.
‘VAT LIABILITY OF STABLING AND LIVERY SERVICES
This Business Brief article explains how Customs and Excise will implement a Tribunal decision on the VAT liability of stabling and livery services supplied together. It updates paragraph 10 of Notice 701/15 (Food for animals).