Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Implementation period definition

What does Implementation period mean? In legal practice, this describes the post‑Brexit window during which EU law continued to apply in and to the UK to ensure continuity for businesses, regulators and litigants while future‑relationship terms were settled. It is a statutory term: section 1 of the European Union (Withdrawal Agreement) Act 2020 adopts the period provided by Part 4 of the Withdrawal Agreement, running from exit day to IP completion day (31 December 2020 at 11 pm UK time: section 39). The UK’s preferred label is “implementation period”; the EU and Ireland generally use “transition period”. Key legal features included continued application of EU law,...

UK VAT: Identifying Single Composite or Multiple Supplies—Tests, Case Law, Rates, Separate Suppliers and Practical Assessment

Published by a LexisNexis Tax expert

Practice notes

Single composite supplies vs multiple supplies

When a supply consists of several components attracting different VAT treatments, a central issue is whether those components should be taxed separately for VAT purposes (a multiple or mixed supply) or whether the bundle should receive a single VAT treatment (a single or composite supply) and, if so, which one applies. This conundrum has repeatedly perplexed the courts, HMRC and taxpayers, and has frequently and regularly reached both the domestic courts and the EU Court of Justice. This Practice Note outlines the present position in law and administrative practice in this area today.

The UK left EU membership on 31 January 2020, and the implementation period—during which, for many purposes, the UK continued to be treated as a Member State—ended at 11pm on 31 December 2020. For guidance on the ongoing significance of EU Directives, and of the Court of Justice’s judgments, for the UK’s VAT rules, see Practice Note: Retained EU law and tax.

Why the need to distinguish between single and multiple supplies?...

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Jo Crookshank

Simmons & Simmons

Jo Crookshank is a VAT partner at Simmons & Simmons LLP and leads the technology, media and telecoms tax practice. Jo specialises in complex technical advice, supply chain and cross-border tax issues....

Gary Barnett

Simmons & Simmons

Gary is a senior professional support lawyer in the corporate tax group at Simmons & Simmons. Before becoming a professional support lawyer, he qualified at another major international law firm and advised on a wide range of corporate tax and VAT matters, with a particular emphasis on M&A transactions. Gary became a professional support lawyer at Simmons & Simmons in 1996 and has since been responsible for developing the knowledge management strategy for the corporate tax group and providing support to the tax teams across Simmons & Simmons international network. Gary has written extensively on a wide range of tax topics and has previously contributed VAT commentary for De Voil Indirect Tax Service....

Web page updated on 22/05/2026

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