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Colaingrove Ltd v HMRC

Sale of caravans: apportionment of consideration

In Colaingrove Ltd v HMRC (No. 5) (TC02746 – 17 June) a company which sold caravans supplied verandahs with some of the caravans which it sold. Initially it accounted for VAT on these verandahs but it subsequently submitted a repayment claim on the basis that it should have treated the verandah as part of the supply of the caravan and as zero-rated. HMRC rejected the claim and the First-tier Tribunal dismissed the company’s appeal. Judge Hellier held that ‘the verandah was neither incidental to nor integral with the caravan’.

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Why it matters: The First-tier Tribunal upheld HMRC’s view that the supply of a verandah intended for use with a zero-rated caravan was a separate supply which failed to qualify for zero-rating. (The company is also currently involved in two cases which are being taken...

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