Books: Printed matter supplied with services: Programmes supplied as part of an admission fee
Following the judgement in Card Protection Plan (CJEC C-349/96) we would expect that in the majority of cases where admission to an event includes the provision of a programme there will be a single supply of admission services, the programme being an ancillary item.
Care should be taken to assure that no artificial supply splitting is taking place. There have been attempts by businesses to get around Card Protection Plan by recourse to the arrangements outlined in the Telewest case (CA STC 481), which ruled that in circumstances where printed matter such as programmes are produced by a separate company to that supplying services such as those of admission in the example above, then they cannot be regarded as a single supply. Under Telewest, the supply of printed matter would be seen as separate and subject to its own liability and not that of the main supply of services.
(Note (2) of Group 3 - Books, etc, VATA 1994 Schedule 8 requires that, in such circumstances, the supply of services and printed matter must be looked at as though they were provided by a single supplier. This essentially restores the Card Protection Plan principles.