Readers' forum: By the book

I act for a one-person limited company client the director of which specialises in providing HR consultancy services mainly to banks and insurance companies which cannot claim input tax.

HMRC has recently reviewed the company’s VAT records and challenged its sales invoices that show one figure for the services supplied (standard rated) and a separate charge for procedural manuals (zero rated as reading material) that the director supplies to the customers to help their HR decision-making. The company has the manuals printed externally at a considerable cost and the printer treats them as zero rated. But the officer says the onward charge by my client should be standard rated as part of the company’s overall service and he has quoted the 1999 ECJ case Card Protection Plan (C-349/96) to support his argument.

Do readers agree with the officer’s view? My client applies a 50% mark-up to...