Single or multiple supplies | Croner-i Tax and Accounting

Additional transport services

Commentary – Indirect Tax Reporter ¶22-375

Apportionment

Distortion of competition

Commentary – Indirect Tax Reporter ¶14-800

Multiple supply

Commentary – Indirect Tax Reporter ¶15-230

HMRC Guidance – Notice 700

Output tax

Commentary – Indirect Tax Reporter ¶15-665

Barbecues

Case Law – Wm Morrison Supermarkets plc v Revenue and Customs Commissioners. [2013] BVC 1,672

Books or magazines packaged with another item

Commentary – Indirect Tax Reporter ¶20-550

Car sold with insurance

Case Law – Peugeot Motor Co plc & Anor v Customs and Excise Commissioners. [2004] BVC 269 ; Peugeot Motor Co plc; Citroën UK Ltd. [1999] BVC 2,314

Card Protection Plan

Commentary – Indirect Tax Reporter ¶14-800

Cases

– see Single or multiple supply cases

Categorising mixed supplies

Commentary – Indirect Tax Reporter ¶14-800

Catering supplied with transport of passengers

Boat trips

Case Law – Hughes & Anor t/a Pennine Boat Trips of Skipton. [1999] BVC 2,003 ; Virgin Atlantic Airways Ltd. [1996] BVC 2,644

Day excursions by train

Case Law – Sea Containers Ltd v Customs and Excise Commissioners. [2000] BVC 60 ; Sea Containers Services Ltd. [1999] BVC 2,214

In-flight catering

Case Law – British Airways plc v. Customs and Excise Commissioners. (1988) 3 BVC 401 ; British Airways plc v. Customs and Excise Commissioners. (1990) 5 BVC 97 ; British Airways plc. (1987) 3 BVC 592

Children's parties, supply of hall with play equipment and catering

Case Law – Bryce t/a The Barn. [2010] TC 00242 ; Revenue and Customs Commissioners v Bryce (t/a The Barn). [2011] BVC 1,589

Compact disc with printed matter

Case Law – International Masters Publishers Ltd v Revenue and Customs Commissioners; R (on the application of International Masters Publishers Ltd) v Customs and Excise Commissioners. [2008] BVC 58

Company formation services

Case Law – J.P. Company Registrations Ltd. (1986) 3 BVC 503

Concession agreement at airports, right to occupy land and sell goods

Case Law – British Airports Authority v. Customs and Excise Commissioners. (1975) 1 BVC 59 ; British Airports Authority v. Customs and Excise Commissioners. (1976) 1 BVC 97

Contracts for hire of television sets and back-up services

Case Law – Thorn EMI plc; Granada plc. [1993] BVC 792

Correspondence course

Case Law – Computeach International Ltd. [1995] BVC 931 ; International News Syndicate Ltd. [1996] BVC 2,988

Credit card protection plan

Case Law – Card Protection Plan Ltd v. Customs and Excise Commissioners. [1992] BVC 157 ; Card Protection Plan Ltd. (1990) 5 BVC 956

Credit card registration service

Case Law – Card Protection Plan Ltd v. Customs and Excise Commissioners. [1994] BVC 20

Customisation of software

Case Law – Levob Verzekeringen BV & Anor v Staatssecretaris van Financiën (Case C-41/04). [2007] BVC 155

Data processing services

Case Law – Laurentian Management Services Ltd; Lincoln Assurance Ltd. [2000] BVC 2,210

Debenture issue

Case Law – Rugby Football Union. [2003] BVC 2,506

Delivery charge ancillary to main supply

Commentary – Indirect Tax Reporter ¶54-050

Delivery, postage and packing charges

Commentary – Indirect Tax Reporter ¶15-215

Different VAT treatments

Standard-rated

Commentary – Indirect Tax Reporter ¶14-800

Zero-rated

Commentary – Indirect Tax Reporter ¶14-800

Diplomatic services

Case Law – Bophuthatswana National Commercial Corporation Ltd v. Customs and Excise Commissioners. [1992] BVC 127 ; Bophuthatswana National Commercial Corporation Ltd v. Customs and Excise Commissioners. [1993] BVC 194 ; Bophuthatswana National Commercial Corporation Ltd. [1991] BVC 513

Disposable nappies in plastic toy box

Case Law – Kimberly-Clark Ltd v Customs and Excise Commissioners. [2004] BVC 626

Distance learning courses

Case Law – College of Estate Management v Customs and Excise Commissioners. [2004] BVC 395 ; College of Estate Management v Customs and Excise Commissioners. [2004] BVC 813 ; College of Estate Management v Customs and Excise Commissioners. [2005] BVC 704 ; Metropolitan International Schools [2015] TC 04675

Drugs and medicines

Administration by doctors

Case Law – Woodings & Ors. [2000] BVC 2,032

Doctors provision and personal administration to patients under reg. 20

Case Law – Beynon & Partners v Customs and Excise Commissioners. [2005] BVC 3 ; Doctor Benyon & Ors. [2001] BVC 2,331 ; Doctor Beynon and Partners v Customs and Excise Commissioners. [2002] BVC 494 ; Dr Beynon and Partners v Customs and Excise Commissioners [2003] BVC 127

Private hospitals

Case Law – British United Provident Association Ltd (No. 1 Drugs). [1995] BVC 990

Educational printed matter

Commentary – Indirect Tax Reporter ¶50-630

Electricity supplied to touring caravans on site

Case Law – J Adams, AC Woskett & Partners. [1993] BVC 786

Exhibitions and sales of paintings

Case Law – Campbell. [1997] BVC 2,517

Feed and labour supplied for racehorses while in training

Case Law – (1985) 2 BVC 200,059

Fire equipment installed at subleased premises

Case Law – Aquarium Entertainments Ltd. [1995] BVC 728

Flowchart

Commentary – Indirect Tax Reporter ¶14-805

Franchisor of activity programme for pre-school children, goods and benefits in return for membership fee

Case Law – Tumble Tots (UK) Ltd v R & C Commrs. [2007] BVC 179 ; Tumble Tots UK Ltd. [2006] BVC 2,673

Funeral services, facilitating and administering arrangements for alternative funeral director

Case Law – Co-operative Wholesale Society Ltd v Customs and Excise Commissioners. [2000] BVC 13 ; Co-operative Wholesale Society Ltd v Customs and Excise Commissioners. [2000] BVC 348

Generally

Commentary – Indirect Tax Reporter ¶14-800 ; Indirect Tax Reporter ¶140(1) ; Indirect Tax Reporter ¶18-004(1)

Golf club

Generally

Case Law – Tall Pines Golf & Leisure Co Ltd. [2000] BVC 2,265

Hairdressing salon

Case Law – Holland (t/a Studio Hair Co) v Revenue and Customs Commissioners; Vigdor Ltd v Revenue and Customs Commissioners. [2009] BVC 3

Handling charge levied on customers of mobile phone network

Case Law – Everything Everywhere Ltd (formerly T-Mobile (UK) Ltd) v Revenue and Customs Commissioners (Case C-276/09). [2011] BVC 44 ; T-Mobile (UK) Ltd [2008] BVC 2,169

Helicopters for use as air ambulances along with pilots and supporting services

Case Law – Medical Aviation Services Ltd. [1998] BVC 2,103

Holiday accommodation including power

Case Law – (1985) 2 BVC 205,330 ; Colaingrove Ltd [2013] TC 02534

Holiday homes

Case Law – Lower Mill Estate Ltd v Revenue and Customs Commissioners. [2011] BVC 1,554 ; Lower Mill Estate Ltd; Conservation Builders Ltd. [2009] TC 00016

Incidental v separate supplies

Commentary – Indirect Tax Reporter ¶14-800

Insurance

Claims handling and training services

Case Law – Equitable Life Assurance Society. [2003] BVC 2,476

Two-year insurance included with sales of cars

Case Law – Lindsay Cars Ltd. [2005] BVC 2,461

Warranty under heating engineer's mechanical breakdown insurance plan

Case Law – Domestic Service Care Ltd. [1995] BVC 745

Insurance and insurance services

Commentary – Indirect Tax Reporter ¶41-700(12)

Kennel facilities

Case Law – Leander International Pet Foods Ltd t/a Arden Grange [2005] BVC 2,273

Kits for growing mushrooms

Case Law – Customs and Excise Commissioners v. Blackpool Pleasure Beach Company. (1974) 1 BVC 1,016

Listings magazine provided by supplier of satellite broadcasting services

Case Law – British Sky Broadcasting plc. [2000] BVC 2,067

Mail order scheme

Case Law – Reece t/a Mako Consultants. [1996] BVC 2,747

Management charges

Commentary – Indirect Tax Reporter ¶18-530

Case Law – TS Harrison & Sons Ltd. [1994] BVC 686

Management courses for foreign executives

Case Law – Customs and Excise Commissioners v. G. & B. Practical Management Development Ltd. (1978) 1 BVC 215

Meal packs sold to hospitals and airlines

Case Law – Hermolis & Co Ltd. (1989) 4 BVC 741

Multiple supply

Commentary – Indirect Tax Reporter ¶14-800

Off-airport parking including courtesy bus/minibus services

Case Law – Purple Parking Ltd, Airparks Services Ltd v Revenue and Customs Commissioners (Case C-117/11). [2012] BVC 268

Opticians

Dispensing services and spectacles/contact lenses

Case Law – Customs and Excise Commissioners v Leightons Ltd; Customs and Excise Commissioners v Eye-Tech Opticians No. 1 & Anor. [1995] BVC 192 ; Leightons Ltd. [1994] BVC 639 ; Leightons Ltd; Eye-Tech Opticians. [2002] BVC 2,027 ; Southport Visionplus Ltd. [2002] BVC 2,047

Fitting out of shops

Case Law – Rayner & Keeler Ltd v. Customs and Excise Commissioners. [1994] BVC 194

Supply of disposable contact lenses and solution by post from Jersey

Case Law – Dollond & Aitchison Ltd. [2004] BVC 2,082

Output tax apportionment

Cost-based

Commentary – Indirect Tax Reporter ¶15-665

Generally

Commentary – Indirect Tax Reporter ¶15-665

Normal selling prices

Commentary – Indirect Tax Reporter ¶15-665

Retrospective re-apportionment of proceeds

Commentary – Indirect Tax Reporter ¶15-665

Outsourced medical care (renal dialysis)

Case Law – Gambro Hospital Ltd. [2004] BVC 2,191

Package holidays

Case Law – (1984) 2 BVC 205,020

Packaging of food

Commentary – Indirect Tax Reporter ¶20-270

Postage and packaging charges

Books

Case Law – (1983) 1 BVC 1,176 ; (1983) 1 BVC 1,177

Mail order bulbs

Case Law – Customs and Excise Commissioners v. Plantiflor Ltd. [1999] BVC 37 ; Customs and Excise Commissioners v Plantiflor Ltd [2002] BVC 572 ; Customs and Excise Commissioners v Plantiflor Ltd. [2000] BVC 103 ; Plantiflor Ltd [1997] BVC 2,380

Presentation folders containing commemorative coins

Case Law – Milk Marketing Board. (1989) 4 BVC 569

Principles established by cases

Commentary – Indirect Tax Reporter ¶14-800

Printed materials consisting of letter and leaflets and envelope

Case Law – Charterhall Marketing Ltd. [2005] BVC 2,566

Private hospitals

Drugs and medicines

Case Law – British United Provident Association Ltd (No. 1 Drugs). [1995] BVC 990

Drugs provided for in-patients and prostheses fitted by surgical intervention

Private school's fee refund scheme

Case Law – Birkdale School, Sheffield v Revenue and Customs Commissioners. [2008] BVC 397

Processing credit card transactions for banks

Case Law – Customs and Excise Commissioners v FDR Ltd. [2000] BVC 311 ; FDR Ltd. [1999] BVC 2,248

Processing credit card transactions: table top or apex supply

Commentary – Indirect Tax Reporter ¶14-800

Promotional services including printed materials

Case Law – Appleby Bowers v Customs and Excise Commissioners. [2001] BVC 341

Real estate consultancy

Case Law – American Express Services Europe Ltd v Revenue and Customs Commissioners. [2010] BVC 381

Restricted supply splitting: printed matter supplied with services

Commentary – Indirect Tax Reporter ¶20-550

Reward scheme

Case Law – Baxi Group Ltd v Revenue and Customs Commissioners. [2007] BVC 267 ; Baxi Group Ltd v Revenue and Customs Commissioners. [2008] BVC 189

Sale of residential caravans and contents

Case Law – Talacre Beach Caravan Sales Ltd v Customs and Excise Commissioners (Case C-251/05). [2007] BVC 366 ; Talacre Beach Caravan Sales Ltd v Customs and Excise Commissioners. [2004] BVC 538 ; Talacre Beach Caravans Ltd. [2003] BVC 2,462

Sale of serviced plots of land to housebuilders

Case Law – Virtue & Anor t/a Lammermuir Game Services [2007] BVC 2,518

Second-hand cars sold with warranty

Case Law – Geddes & Anor. (1989) 4 BVC 573

Service charges

Case Law – Field Fisher Waterhouse LLP v Revenue and Customs Commissioners (Case C-392/11). [2012] BVC 292

Single payment for two supplies

Commentary – Indirect Tax Reporter ¶15-205

Single supply

Exempt and taxable elements: taxable trumps exempt

Commentary – Indirect Tax Reporter ¶14-800

Generally

Commentary – Indirect Tax Reporter ¶14-800

Single composite supply, types of

Commentary – Indirect Tax Reporter ¶14-800

Types of

Commentary – Indirect Tax Reporter ¶14-800

Single supply taxed at two rates

Commentary – Indirect Tax Reporter ¶14-800

Solicitors' services in connection with corporate restructuring exercise

Case Law – Telent plc; Clifford Chance LLP (third party). [2007] BVC 2,262

Stabling and livery services

Case Law – Window. [2001] BVC 2,299

Star registration gift pack

Case Law – Schoemann ISR (UK) Ltd. [1995] BVC 659

Stud farm providing stud services/food and keep

Case Law – Commissioners of Customs & Excise v. Scott. (1977) 1 BVC 139 ; Customs and Excise Commissioners v. Bushby. (1978) 1 BVC 158

Substance and reality

Different supplies

Commentary – Indirect Tax Reporter ¶14-800

Incidental to or an integral part of overall supply

Commentary – Indirect Tax Reporter ¶14-800

Supply splitting

Commentary – Indirect Tax Reporter ¶14-800

Surrender/acquisition of lease

Case Law – Grantham Cricket Club. [1995] BVC 1,046

Teaching English as a foreign language

Case Law – Pilgrims Language Courses Ltd. [1997] BVC 2,116

Teaching materials

Case Law – (1983) 1 BVC 1,183 ; Odhams Leisure Group Ltd v. Customs and Excise Commissioners. [1992] BVC 11 ; Odhams Leisure Group Ltd. (1989) 4 BVC 806

Television services and listings magazines

Case Law – Telewest Communications plc & Anor v Customs & Excise Commissioners. [2005] BVC 156 ; Telewest Communications plc & Anor v Customs and Excise Commissioners. [2004] BVC 342 ; Telewest Communications plc; Telewest Communications (Publications) Ltd. [2003] BVC 2,296

Timeshare facilities supplied to individual timeshare owners

Case Law – Clowance Owners Club Ltd. [2005] BVC 2,169

Trading rights

Case Law – Cullens Holdings plc. [1995] BVC 1,083

Training in UK of overseas personnel

Case Law – Jadecase Ltd. [1992] BVC 876

Transport

Boat trips with catering

Case Law – Hughes & Anor t/a Pennine Boat Trips of Skipton. [1999] BVC 2,003 ; Virgin Atlantic Airways Ltd. [1996] BVC 2,644

Club membership related to international transport

Case Law – El Al Israel Airlines Ltd. [1996] BVC 2,031

Holiday cruise

Case Law – Customs and Excise Commissioners v Peninsular and Oriental Steam Navigation Co (No. 2). [1996] BVC 206 ; The Peninsular & Oriental Steam Navigation Co (No. 2). [1996] BVC 2,435

Limousine transfer service

Case Law – Virgin Atlantic Airways Ltd v Customs and Excise Commissioners; Canadian Airlines International Ltd v Customs and Excise Commissioners. [1995] BVC 93 ; Virgin Atlantic Airways Ltd. [1994] BVC 691

Steam trains running as attraction for enthusiasts and tourists

Case Law – Great Central Railway (1976) plc. [1995] BVC 571

Transport and admission to disused coalmines

Case Law – Big Pit (Blaenafon) Trust. [1992] BVC 565

Try to get ruling from HMRC

Commentary – Indirect Tax Reporter ¶14-800

Two-part tariff

Case Law – (1977) 1 BVC 1,058x

Water supply by landlord

Case Law – Revenue and Customs Commissioners v Honourable Society of Middle Temple. [2013] BVC 1,690

Wedding reception facilities

Exclusivity fee paid to hotel

Case Law – Blendhome Ltd t/a Stanhill Court Hotel. [1999] BVC 2,280

Weight loss programme

Case Law – David Baxendale Ltd [2009] BVC 2,086 ; David Baxendale Ltd v Revenue and Customs Commissioners. [2009] BVC 115 ; David Baxendale Ltd v Revenue and Customs Commissioners. [2009] BVC 663 ; Revenue and Customs Commissioners v Weight Watchers (UK) Ltd. [2008] BVC 254 ; Revenue and Customs Commissioners v Weight Watchers (UK) Ltd. [2009] BVC 91 ; Weight Watchers (UK) Ltd. [2007] BVC 2,383

Welfare services for benefit of elderly

Case Law – Age Concern Leicestershire & Rutland [2009] BVC 2,109