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A multiple or mixed supply has been defined as a single transaction involving the supply of a number of separable goods or services. Each supply must be considered as an independent supply for tax purposes, the single consideration being apportioned as appropriate¹. For the principles used by the courts in distinguishing multiple supplies from composite supplies, see V3.105.

Clearly taxpayers, whose customers (direct or otherwise) are unable fully to recover any tax charged to them, are likely to argue that they are making a single supply, where the amount of tax on that supply is less than it would be, were the transaction(s) regarded as multiple supplies. For example, food manufacturers might argue that they are making a single zero-rated supply of food, rather than multiple supplies of zero-rated food and standard-rated packaging (see United Biscuits (UK) Ltd²).

On the other hand, they are likely to argue that they are making a multiple supply, where the amount of tax on that supply is less than it would be, were the transaction(s) regarded