Input tax on building let to the students’ union

The school carried out a redevelopment project which consisted of the demolition of two buildings the part demolition of the Assembly Building and the construction of a new one known as the Reid Building. The latter was in effect wrapped around the Assembly Building shell of which all that was retained were the facades on three sides and the roof. The only common facilities for the two buildings were the sprinkler and air handling systems which were centralised in the Reid Building and the heating which was centralised in another nearby building together with that for other premises. 

The appeal concerned whether the works carried out on the Assembly Building constituted a separate supply and if so whether the input tax on that supply was recoverable.

The First-tier Tribunal found against the taxpayer so it appealed to the Upper Tribunal.

The...