“…g considered) but where it does, the principal/ancillary test set out by the CJEU in Card Protection Plan Ltdv Customs and Excise Commissioners (Case C-349/96) [1999] 2 AC 601 (“CPP”) is also an available test, but in most cases where this test applies, the predominant element test will also apply and produce the same result. The UT …”
“…es a single service from an economic point of view should not be artificially split” (Case C-349/96 Card Protection Plan Ltd v Customs and Excise Commissioners [1999] 2 AC 601, at paragraph 29 of the judgment). There is therefore a single supply where “two or more elements or acts supplied by the taxable person to the customer are so…”