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Composite and single supplies—meaning

A composite, or single, supply has been defined as a supply in which there is a number of constituent elements, some of which, if supplied separately, would have been taxed, and some not (or taxed at different rates). The implication that a single supply is taxed at a single rate is not necessarily true (see 'Single supply—differing liability' below). In Hurlingham Club¹, it was held that it is necessary to determine the quality of the final composite or compound supply for tax purposes, regardless of its constituent elements.

In fact, the distinction between a composite supply and multiple supplies may significant, not just in determining the tax liability, but also in connection with the place and time of supply. For example, there may be a single tax point for a composite supply of goods, but multiple tax points if there are supplies of both goods and services, or multiple supplies of either. For example, see Laurentian Management Services Ltd and Lincoln Assurance Ltd². See also RDS