VAT: developments on single v multiple supplies

David Anderson

Nicole Kostic

Speed read

The recent decision of the First-tier Tribunal in Colaingrove Ltd provided a further development on the single versus composite or multiple supply analysis. The case joins a slowly developing body of case law which includes decisions of both the CJEU and the Privy Council. Applying the CJEU’s reasoning in EC v France (C-94/09), the tribunal in Colaingrove held that its supply of electricity and water was concrete and specific and therefore liable to the reduced rate of VAT. The Upper Tribunal in WM Morrison Supermarkets plc [2013] UKUT 247 (TCC), however, considering a similar issue, preferred the test from Card Protection Plan.

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