Fees which the Appellant received from credit cardholders were found to be consideration for a single supply of insurance services. After quoting the statement in Customs & Excise Commissioners v. Madgett, [1998] BTC 5440 that "a service must be regarded as ancillary to a principal service if it does not constitute for customers an aim in itself, but a means of better enjoying the principal service applied", Lord Slynn found (at p. 5090) that:
"If one asks what is the essential feature of the scheme or its dominant purpose, perhaps why objectively people are likely to want to join it, I have no doubt it is to obtain a provision of insurance cover against loss arising from the misuse of credit cards or other documents."
Various other services the cardholder was entitled to receive related to the administration of the scheme and were "ancillary or incidental to the main objective of the scheme, i.e., financial protection against loss".