The CPP principle: lessons from Brockenhurst and Colaingrove

The principle laid down by the CJEU in CPP – that a transaction comprising two (or more) items is treated as a single composite supply with a single VAT treatment where one item is the principal component to which the others are ancillary – is well-known. Two judgments delivered on the same day in May – the Court of Appeal judgment in Colaingrove and the CJEU judgment in Brockenhurst College – consider the interaction between this principle and certain specific legislative provisions namely VATA 1994 s 29A and Sch 7A Group 1 and PVD article 132 respectively. Colaingrove confirms that the CPP principle prevails unless there is specific wording in the national legislation dual-rating a single composite supply which includes an ancillary component that is normally reduced-rated. Brockenhurst suggests that the CPP principle is capable of applying to transpose the VAT treatment of a principal supply to an ancillary...