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Central Sussex College v HMRC

Zero-rating and phased construction

In Central Sussex College v HMRC [2014] UKFTT 1058 (27 November 2014) the FTT found that a construction project carried out in phases did not fall within the scope of zero-rating.

The issue was whether redevelopment work undertaken for a college was zero-rated under VATA 1994 Sch 8 Group 5 item 2 as the building was to be used for a ‘relevant charitable purpose’.

The project had been divided into phases and a long lapse of time had passed between the completion of the first two phases and the completion of the third phase; although planned this third phase had depended upon the availability of funding. The first two phases were dedicated to the construction of a new performing arts centre together with a new art and media department. These new buildings were to be used together with the original main...

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