Single or multiple supplies ― other considerations

Produced by a Tolley Value Added Tax expert

Value Added Tax

Guidance

This guidance note looks at the other issues that need to be considered when determining whether a single or multiple supply is being made. This guidance note should be read in conjunction with the Single or multiple supplies ― overview, Single or multiple supplies ― indicators that it is a single or multiple supply and Multiple supplies ― output tax apportionment guidance notes.

Can a single supply have more than one VAT liability applied?

Normally, if a single supply is being made then it can only have one VAT liability applied to it; however, there are limited exceptions to this rule where UK legislation has restricted the scope of the zero rate, reduced rate or exemption.

The CJEU judgment in Talacre Beach Caravan Sales Ltd provides an example of a situation where this has occurred.

This case confirmed HMRC’s view that a single composite zero-rated supply that included a component which was specifically blocked by the legislation from being zero-rated must be apportioned between the zero-rated and standard-rated items. It is not possible

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