My client is an overseas charity seeking to buy premises in the UK where it can house and feed homeless people. Overseas it also trades through a company selling caravans and igloos to house people. A local surveyor has identified premises which the charity would like to purchase and develop in the UK. Half the building would be a hostel used for charitable purposes and half a factory and showroom where it would produce and sell its popular range of caravans and igloos. The client has incurred considerable amounts of VAT including surveyors planning consultants lawyers and the property itself is opted for VAT. If the deal proceeds it will suffer around £2.5m of VAT £2.2m of which is referable to the property. I am instructed to recover 50% referable to the business part of the operations. HMRC is...