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Annex or extension

13 November 2017
Issue: 4624 / Categories: Tax cases

Litton and Thorner’s Community Hall (TC6101)

Claim for zero rating on a storage building for a community hall

A community village hall was built at Litton Cheney in 2009. The plans had included a separate storage building but this was not built at the time because of a lack of funds. Instead it was completed in 2014.

The taxpayer claimed the work should be zero rated on the basis that it was an annexe intended for relevant charitable purposes and met the conditions in VATA 1994 Sch 8 Group 5 note 17(a) and (b). Builder services to construct an extension are standard rated.

HMRC refused the claim so the taxpayer appealed.

The First-tier Tribunal noted that the work on the original building had qualified for zero rating as a village hall or similar use for a relevant charitable purpose. The judge decided the additional building was an annexe and compared it to a ‘garage being...

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