Realreed Ltd (TC9013)
The Chelsea Cloisters building consists of 656 apartments and 421 were rented out on long-term leases to tenants who lived there so the income for the taxpayer was exempt from VAT as a land supply for these apartments. However the other 235 apartments were rented out to ‘occupiers’ who needed shorter stays often from the corporate world. The occupiers paid a daily rate for the fully furnished accommodation provided by the taxpayer and were not charged either council tax or utility bills. Other services such as daily cleaning luggage storage and clean linen were charged by a company under common ownership with the taxpayer - namely Chelsea Cloisters Services Ltd (CCS).
CCS treated these services were treated as VATable but the taxpayer treated its own rental supplies to the occupiers as exempt from VAT. HMRC’s view was that the accommodation provided by the taxpayer...
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.