In The Ice Rink Company Ltd and PI (Milton Keynes) Ltd [2017] TC06117, the FTT agreed with the taxpayer that the supply of access to the ice rink and hire of skates were two separate supplies.

  • Users of the ice rink could bring their own skates, or, for an additional fee, hire skates.
  • Where skates were hired a single increased price was paid for access to the rink and hire of skates.
  • HMRC argued that the hire of skates was ancillary to the access, and this was evidenced by the fact that a single price was paid.
  • HMRC therefore took the view that it was a single standard rated supply and not a Multiple supply.

The FTT agreed with the taxpayer and looked to the fact that half of the skaters brought their own skates.

  • It was not artificial to separate the package into two, they were separable because not all customers needed both.
  • Neither supply is ancillary to the other.

The taxpayer's appeal was allowed. This meant that where the skates were hired by children, that proportion of the fee could be zero-rated.


Single or multiple supply?

External link: The Ice Rink Company Ltd and PI (Milton Keynes) Ltd [2017] TC06117


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