Can a massage parlour be considered a taxable supply?

In Manship Holdings v. The Queen,[6] the appellant, who operated a massage parlour, allowed the masseuses, who were considered to be self-employed, to use its facilities. The appellant claimed that the massages were supplied by the masseuses and that the appellant only provided the facilities, which, in its view, was not a taxable supply. One of the issues was the relationship between the supply of the facilities and the supply of the massages, and whether a single supply or multiple supplies were made. At paragraph 34, Justice Angers wrote: In the case at bar, one must ask if the supply of the massage along with the supply of the premises constitutes a single supply or multiple supplies. Is it possible or realistic to omit one component from the overall supply? In our fact situation, the appellant could not supply or offer massage services without, or independently from, the use of the premises; thus, both elements are highly interconnected and interdependent. The true nature of the transaction for which consideration was paid was the supply of the massage, which, in the fact situation here, cannot be made without the use of the appellant's premises. The supply of the premises to the customers cannot stand by itself or be omitted from the overall supply of the massage. In other words, the fact situation of this case would make it impossible to purchase each of the supplies or elements separately and still end up with a useful service. The end result is that the supply in the case at bar is a compound supply whose elements cannot be separated for tax purposes. [Emphasis added.]