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The Marketing Lounge Partnership Ltd (TC4411)
The taxpayer organised promotional campaigns which offered various incentives for customers such as free hotel accommodation and spa treatments.
The company maintained that it provided a mixed supply: a zero-rated supply of goods relating to printed matter such as hotel guides and a standard-rated supply of “fulfilment services” comprising the distribution of documentation administration and assistance.
HMRC argued that there was a single standard-rated supply of promotional services and that the reading material was an ancillary item.
Referring to the decision in Card Protection Plan Ltd v CCE (Case C-349/96) [1999] STC 270 the First-tier Tribunal decided the company made a single supply of standard-rated promotional and marketing services and this was the core activity of the business. By engaging the taxpayer the client was relieved of the responsibility...
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