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Chelsea Cloisters Management Ltd v HMRC

FTT had no jurisdiction to apply extra statutory concession.

In Chelsea Cloisters Management Ltd v HMRC [2025] UKFTT 205 (TC) (12 February) the FTT concluded that it had no jurisdiction in respect of a disputed application of an extra-statutory concession. The FTT however opined that if it did have jurisdiction it would have found in favour of the taxpayer.

Chelsea Cloisters Management Ltd (CCML) is a management company for a property in London known as Chelsea Cloisters. Although other aspects were considered in a detailed discussion the crux of the appeal related to the VAT liability of supplies made by CCML and the resultant VAT registration requirement. HMRC decided that CCML had been making supplies of management services chargeable at the standard rate  and CCML should have been compulsorily VAT registered.

CCML argued that its supplies fell within a VAT extra-statutory concession covering domestic service charges (Extra Statutory Concession (ESC) 3.18) and were...

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