Multiple supplies: The issue in GAP Group Ltd v HMRC [2023] UKFTT 970 (TC) (2 November 2023) was whether a plant hire company was making multiple supplies of plant hire and red diesel. The effect would be that the plant hire was standard rated but the reduced rate would apply to the fuel. The company’s practice was to provide vehicles to hirers with fuel in the tank. At the end of the hire if the hirer returned the vehicle with less fuel in the tank than there had been at the outset a charge was made for the difference. The FTT applied the principles considered in Honourable Society of Middle Temple and allowed the company’s appeal. Reading the FTT’s consideration of the Middle Temple principles will be well worth the time not least because the company maintained that it was applying standard industry practice. Key issues included...
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