VAT

The issue of whether a contract involved the provision of one or more supplies for VAT purposes and other issues relating to place of supply were issues of legal evaluation, and therefore issues of law, that might require a multi-factoral assessment based on a number of primary facts so that the appeal court should be slow to interfere with that overall assessment and should not re-open primary findings of fact

The issue of single or multiple supply had to logically be determined as a pre-requisite to addressing the issue of place of supply. The starting point was that every supply of goods and services had to be regarded as distinct and independent.

The relevant transactions had to be analysed with due regard to all the circumstances in which they took place and the essential features of the transaction had to be considered at a level of generality that corresponded to economic reality, objectively, and from the perspective of