Case Analysis – HMRC v The Honourable Society of Middle Temple [2013] UKUT 250


The issue in this case was whether the supply of cold water to barristers’ chambers formed part of a single supply of the leased premises or the separate supply of water. The case provides a detailed analysis of the legal principles to be applied in the UK with respect to the single/multiple supply issue. Noting the reservations of Courts with regard to relying on overseas authorities in taxation cases, these legal principles have been accepted and applied by the Federal Court in cases such as Saga Holidays and also by the Commissioner in various rulings. This decision helpfully brings those principles together and provides an update on the current position of the law.

The Facts



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