Many readers will have heard of the long series of Tax Tribunal and Higher Court decisions concerning where a supply consists of a number of identifiable elements. Card Protection Plan being the most significant early case. (see: www.bailii.org/eu/cases/EUECJ/1998/C34996_O.html)
The Court of Appeal has considered this question and added comment on the ‘place of supply’ rules in Gray & Farrar International LLP. ([2023] EWCA Civ 121)
The decision is not long and is worth a read, especially if you have clients whose customers are predominantly private persons located outside the UK.
Source Accountingweb
