In Metropolitan International Schools v Revenue and Customs  UKFTT 517 the Tribunal considered the often difficult question of whether a transaction was to be properly characterised as a single supply – and if so, a single supply of what?
The taxpayer provided distance learning courses and, while both parties agreed that there was a single supply, the taxpayer contended that there was a single supply of manuals (books are zero rated or GST-free) and the Revenue contended that there was a single supply of education (taxable, not being within the exempt education provisions).
In coming to the view that there was a single supply of books, the Tribunal conducted a detailed review of the case law and the principles involved in determining the characterisation of a transaction. While caution must be had when having regard to overseas authorities, the approach of the Tribunal and the principles adopted do provide assistance on how similar issues may be resolved in Australia.
My analysis of the decision can be accessed here.