VATVAL03300 - Apportionment of monetary consideration: is there more than one supply?

Although in some cases it will be clear that a single payment is the consideration for more than one supply, this is not necessarily the case. You should take particular care that a single supply is not artificially divided into several supplies in an attempt to make part of the consideration liable to zero-rating or exemption.

If you are unsure whether or not there is a single supply, you should consult VATSC11100: “Supply and consideration”. Following the CJEU decision in Talacre Beach Caravan Sales Ltd case C-251/05 there is potential for apportionment in circumstances where there is only a single supply if this would result in extending the application of a zero rate beyond its intended purpose. Please refer to VATSC11170 and VATVAL11300 for caravan issues in particular.