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HMRC internal manual

VAT Valuation Manual

Apportionment of monetary consideration: is there more than one supply?

Although in some cases it will be clear that a single payment is the consideration for more than one supply, this is not necessarily the case. You should take particular care that a single supply is not artificially divided into several supplies in an attempt to make part of the consideration liable to zero-rating or exemption.

If you are unsure whether or not there is a single supply, you should consult VATSC80000: “Supply and consideration”. Following the CJEU decision in Talacre Beach Caravan Sales Ltd case C-251/05 there is potential for apportionment in circumstances where there is only a single supply if this would result in extending the application of a zero rate beyond its intended purpose. Please refer to VATSC80400 and VATVAL11000 for caravan issues in particular.