Key points
- Supplies often have different elements that may have different VAT rates.
- When is a multiple supply treated as a single supply?
- A typical customer must be the recipient of the relevant supplies.
- Are multiple supplies presented as a single package?
- If elements are separable they may be treated as individual supplies.
Ask most VAT practitioners which areas of VAT continue to have the most interesting array of disputes and single/multiple supply debates would probably be quite high up the list.
The issue has led to many famous cases both domestically and in Europe and there seems to be no let-up in sight given the factual sensitivities in each case. Perhaps this is because the issue stimulates the mind without the need to trawl through vast amounts of legislation. Two recent cases have focused on the issue but before discussing them further a...