19 December 2003 Headquarters Letter Case No. 45870

Discussion as to whether electricity supply contracts under which there were separate charges for capacity and electricity would represent a multiple or single supply.

Charges for electrical capacity, if regarded as consideration for a supply separate from a supply of electricity, would represent consideration for intangible personal property (rather than tangible personal property as would be the case for a supply of electricity) and, therefore, would not be eligible for zero-rating, and would be governed by s. 142(1)(c) rather than (a).