VAT: developments on single v multiple supplies

The case law on the analysis to be applied to a single multiple or a composite supply to determine the VAT liability of part or all of the supply has undergone some iterative developments since the seminal case of Card Protection Plan (C-349/96) [1999] STC 270 (CPP). We seek to plot these developments offer a view on the principles that have been used and consider what this may mean for the future.

Developments since CPP

At the time CPP was decided by the CJEU it was thought that it was to be a complete test for all single versus multiple supply issues. It soon became apparent that not only was that not the case but...