Selling Software on CD/USB drive, is it supply of goods or service?

Dear HMRC colleagues, We provide software, both on CD/USB drives and online. Our customers are both individual customers and business customers. We read “VAT rules for supplies of digital services to consumers” https://www.gov.uk/guidance/the-vat-rules-if-you-supply-digital-services-to-private-consumers#define-digital It is said that “Electronically supplied services. These rules only apply to e-services that you supply electronically and include things like:… supplies of software and software updates” Therefore, my first question is that: whether supplying software on CD/USB drive should be counted as a supply of service or a supply of goods? It also states that “If you accept that your customer is in business, the supply does not come within the scope of these business-to-consumer arrangements. “ Therefore, my second question is that: If it is a B2B supply of software, should we follow the normal VAT notice 741A general service supply rules? Thank you very much for your clarification. Best regards,

Hi Andy,
The mailing of CDs and USB sticks to customers is a supply of goods, the place of which will be determined by the rules in s.7 of the VAT Act 1994. If, as a consequence of the software on those tangible media being uploaded by the customer, the business is then able to supply digital services to that customer, the place of supply of those services will be determined separately.
A business in this position would need to work out whether it is making
•    a single, “bundled” supply of the 
    tangible media plus 
    the consequent digital services, or
•    two separate supplies. 
Please see the guidance below:
VATSC11100 - Supply: Single and multiple supplies: Contents
If you are  unable to reach a confident conclusion, and believe that VATSC11100 includes genuine points of uncertainty in respect of its particular situation, you will have the option of submitting a request for a non-statutory clearance.
Please see the guidance below:
Information you need to give
Thank you.