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The CPP principle: lessons from Brockenhurst and Colaingrove

Etienne Wong (Old Square Tax Chambers) considers what the CJEU judgment in Brockenhurst College and the Court of Appeal judgment in Colaingrove say about the CPP principle.
 

In the VAT world CPP is almost as well-known an acronym as PVD and VATA. Few even refer to the case by its full name – Card Protection Plan (Case C-349/96) – where the principle was laid down by the CJEU that a transaction comprising two (or more) items would be treated as a single (composite) supply with a single VAT treatment – even where the items in question if supplied on their own would each have a different VAT treatment – provided that one of the items is the principal component to which the others are ancillary.

This principle was referenced in two recent judgments – the judgment of the Court of Appeal in Colaingrove [2017] EWCA CIv 332...

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