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HMRC internal manual

VAT Insurance

HM Revenue & Customs
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Insurance with other goods and services: Single and Multiple Supplies: European Court of Justice (ECJ) Judgement in Card Protection Plan Ltd (CPP)

This case provides the most authoritative guidance yet for determining whether there are single or multiple supplies.

Card Protection Plan Ltd (CPP)

This case concerned the provision of a package of goods and services making up a credit card protection plan. These goods and services included:

  • keeping records of customer information;
  • property tags for keys and luggage;
  • world wide medical assistance;
  • delivery of emergency cash and tickets;
  • car-hire discounts;
  • insurance effected under a block policy against unauthorised use of credit card; and
  • insurance effected under a block insurance policy to cover communication costs in the event of loss of valuables.

We ruled that there was one standard rated supply and CPP appealed on the grounds thatthe greater part of the supply was exempt as the making of arrangements for the provision of insurance. The case proceeded through the courts until it reached the House of Lords where a reference was made to the ECJ. The ECJ was asked to decide on four questions:

Questions 1 and 2 were considered together and concerned the single/ multiple supply issues – see VATINS7120.

Question 3 asked whether services such as those made by CPP under a block insurance policy constituted insurance transactions or the related services of insurance agents – see VATINS2300.

Question 4 asked whether the UK could restrict their exemption to supplies by insurers whoare authorised by national law to pursue the activity of insurer – see VATINS1510.

Based on the findings of the ECJ, the House of Lords found in favour of CPP and ruled the provision of the card protection plan was a single supply of exempt insurance transactions (not related services as originally argued by CPP).