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Carson Contractors v HMRC

Protected building: barn conversion

In Carson Contractors v HMRC [2015] UKFTT 530 (30 October 2015) the FTT found that zero-rating under VATA 1994 Sch 8 Group 6 item 2 was not available on the restoration of a barn.

Carson appealed against VAT assessments relating to supplies of construction services which it argued were zero-rated as the approved alteration of a protected building.

The purpose of the works carried out by Carson (as described in the planning application) had been a barn conversion ‘to provide ancillary accommodation for the family at Bridges Court’ which was a listed building. The planning permission had provided that the annexe could not be occupied other than in conjunction with the house and could not be sold separately.

The issue was whether the house and the annexe were two separate dwellings. The FTT noted that the test in item 2 did not...

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