Colaingrove, the reduced rate of VAT and composite supplies

The recent Upper Tribunal decision in Colaingrove addressed some fundamental questions about the underlying analytical foundations of the VAT system. The decision may have profound implications for suppliers of goods or services which fall to be taxed at a lower rate, but which are provided together with other elements which are taxed at the standard VAT rate. The tribunal considered the interaction between two lines of CJEU cases dealing with applying differential VAT rates to different elements of a composite supply. Its conclusion presents both risks and opportunities for a broad spectrum of taxpayers, who may need to review their contractual arrangements to protect the application of lower VAT rates to their supplies.