The taxpayer, which sold horticultural products by mail order, indicated in its catalogue that customers would pay an additional charge to cover the costs of postage and packing, and stated "We will then advance all postage charges to Royal Mail on your behalf."
After finding that there in fact was only one supply involved (of delivered bulbs) Lord Slynn went on to find that, even if there were two supplies, the portion of the money received by the taxpayer for postage constituted part of the consideration received by it for the supply of the bulbs. The argument that the taxpayer received that portion as agent for the Royal Mail was contrary to the terms of the agreement between it and the Royal Mail, which made it clear that the Royal Mail was to deliver parcels for the taxpayer, i.e., there was no link between the Royal Mail and the customer.