Colaingrove v HMRC

In Colaingrove v HMRC [2015] UKUT 0002 (15 January 2015) the UT found that supplies of verandas together with caravans were zero-rated.

Colaingrove sold ‘static caravans’ that were zero-rated under VATA 1994 sch 8 group 9. The issue was whether supplies of verandas (which were bolted to the caravans and sometimes also fixed to the ground) were also zero-rated.

The principal question was whether the supply of a caravan together with a veranda was a single supply. The FTT (applying Talacre Beach Caravan Sales (C-251/05)) had found that the veranda was not ‘subordinate’ to the caravan and therefore its supply was not zero-rated.

The UT noted however that Talacre had not ‘jettisoned’ the CPP principles (drawn from the Card Protection Plan (C-349/96) case). These were not relevant when establishing whether a single supply had taken place but applied when deciding whether the national legislation had...