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Single supply
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Single supply
SINGLE-SUPPLY
Inter-company outsourcing under scrutiny: VAT perspective after JPMorgan
Philippe Gamito
Philippe Gamito (Baker McKenzie) reviews an Upper Tribunal decision
which is likely to shape the way international businesses design in-house
outsourcing strategies.
Queenscourt Ltd v HMRC
VAT: single or multiple supplies
The VAT review for February 2026
Jo Crookshank
Gary Barnett
This month’s update by Jo Crookshank and Gary Barnett (Simmons & Simmons) covers share sales, substance over form and single supplies.
The VAT review for July 2024
Gary Barnett
Joao Martinho
Recent VAT decisions on card handling fees, single supply determinations and fixed establishments are reviewed by Joao Martinho and Gary Barnett (Simmons & Simmons).
Spectrum Community Health CIC v HMRC
Healthcare service provided in prisons was a single supply for VAT.
Other cases that caught our eye: 14 June 2024
VAT on KFC sauce pots: Queenscourt Ltd v HMRC [2024] UKFTT 460 (TC) (3 June 2024) concerned whether a supply of a sauce pot with a takeaway meal in a Kentucky Fried Chicken franchise was part of a standard rated supply of hot food or a separate...
Characterising a single supply following the Court of Appeal’s decision in Gray & Farrar
Sarabjit Singh
The Court of Appeal’s decision is likely to remain authoritative guidance
for some time on the question of how a single complex supply ought to be
characterised, writes Sarabjit Singh KC (1 Crown Office Row).
Single supply and VAT exemption for financial services: insights from JPMorgan
Anastasia Nourescu
Naima Khalid
Naima Khalid (EY) and Anastasia Nourescu (Stewarts) consider the impact
of the recent decision in JPMorgan.
Characterising supplies for VAT following Mesto Zamberk
Michael Thomas KC
The characterisation test for VAT has received important clarification from the Court of Appeal, writes Michael Thomas KC (Pump Court Tax Chambers).
BlackRock: single supply, dual use – apportionment?
Etienne Wong
Etienne Wong (Old Square Chambers) examines the CJEU’s decision concerning VAT on a single supply of investment management services used to manage both special investment funds and non-SIFs.
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EDITOR'S PICK
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
1 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
2 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
3 /7
Loopholes and tax avoidance
Kyle Rainsford
4 /7
Spare us the cUTTer
Nick Thornton
5 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
6 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
7 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Loopholes and tax avoidance
Kyle Rainsford
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
NEWS
Read all
Tax Update 2026: government publishes simplification and compliance package
HMRC asked to clarify CIS treatment of development finance
HMRC Transfer Pricing and Profit Diversion Compliance Facility
ICTS consultation
UK-India Double Contributions Convention arrangements extended
CASES
Read all
HMRC v HFFX LLP; Atkins and others v HMRC
The Trustees of the Panico Panayi Accumulation and Maintenance Settlements Nos. 1 to 4 v HMRC and Redevco Properties UK 1 Ltd v HMRC
Other cases that caught our eye: 26 June 2026
HMRC v Bolt Services UK Ltd
Barclays Bank plc v HMRC
IN BRIEF
Read all
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
Information notices
Management rollovers and share-for-share exchange relief
MOST READ
Read all
Solving the LLC double taxation problem
Consultation tracker
Foreign PE exemption becoming mandatory
HMRC v GCH Corporation Ltd and others
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’