According to its previous case law, the court stated that, in the absence of quite exceptional circumstances, services linked to the practice of sport or physical education must, as far as possible, be considered as a whole (ie a single supply). As such, where ‘other’ services are provided in addition to making the facilities available, they are to be regarded as the main service supplied. The Court therefore concluded that as 80% of the value charged to the football club for the use of the stadium was associated with these ‘other’ services, the supply was not to be regarded as an exempt letting of the property, but as a taxable supply of services.
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