In a case concerning holiday accommodation, HMRC has successfully argued that the holiday park owner was acting as principal in the supply of accommodation owned by individual home owners, resulting in a significantly increased VAT liability for the park owner.
However in my view the Tribunal may not have been asked to consider all the relevant issues, and in particular TOMS. I would be happy to speak to other businesses in a similar position.
http://financeandtax.decisions.tribunals.gov.uk/judgmentfiles/j10105/TC06136.pdf
