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The taxpayer leased serviced offices in London. The landlord treated the supplies of immovable property and services as being exempt from VAT.
The taxpayer considered that the supplies of services by the landlord were subject to VAT and applied to HMRC to reclaim the tax paid in respect of them.
The Revenue refused on the ground the lease and the supplies of services constituted a single supply which was exempt from VAT.
The taxpayer appealed to the First-tier Tribunal which referred the matter to the European Court of Justice (ECJ).
The ECJ said that for VAT purposes every supply should normally be regarded as distinct and a supply should be regarded as single where two or more elements were so closely linked that they formed a single economic supply which it would be artificial to split.
The leasing of immovable property and the supplies...
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