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Reverse VAT confusion

The abandonment of the reasoning in Lubbock Fine & Co v Commissioners of Customs and Excise [1994] STC 101 by the European Court of Justice in three cases in early October 2001 (Stichting Goed Wonen v Staatsecretaris van Financien C-326/99 Commissioners of Customs and Excise v Mirror Group plc and Commissioners of Customs and Excise v Cantor Fitzgerald International [2001] STC 1453) may not have a great deal of effect in cases concerning reverse premiums or reverse assignments. This is because the status of many reverse premiums was in doubt on a second issue namely whether works were being carried out on behalf of the landlord as part and parcel of the composite arrangement.

Reverse assignment situations in which one of the parties did not have other premises in the same building were normally dealt with to the...