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HMRC internal manual

VAT Supply and Consideration

Supply: Whether supplies are goods or services: Transfer of an undivided share of title in goods

This refers to goods that can be owned equally by more than one person, that is where the title to the goods is shared. The most commonly arising supply of an undivided share in goods concerns horses. In normal circumstances, for example, where an item such as a fridge is bought equally by more than one person, the title to the goods can only rest with one person. If all the shares in an equally owned good are simultaneously sold to one person this would be a supply of goods as normal, but if only one of the part shares is sold, title to the goods does not pass to the new owner of the part-share. As title does not pass, this supply is not of goods but of services.