In HMRC v Fortyseven Park Street [2019] EWCA Civ 849 (17 May 2019) the Court of Appeal reversing the UT’s decision found that the supply of a right to occupy a residence up to a maximum number of nights per year together with hotel-like services was not an exempt supply of land (VATA 1994 Sch 9 Group 1).
Fortyseven Park Street sold ‘fractional interests’ in residences at 47 Park Street in Mayfair. In return for a substantial upfront price a purchaser acquired the ability to occupy a residence at the property of a specified category for a maximum number of nights in each year until 31 October 2050 and to access a range of related benefits during that period. These included the option for the purchaser to exchange stays at the property for stays in other properties and to realise rental...
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In HMRC v Fortyseven Park Street [2019] EWCA Civ 849 (17 May 2019) the Court of Appeal reversing the UT’s decision found that the supply of a right to occupy a residence up to a maximum number of nights per year together with hotel-like services was not an exempt supply of land (VATA 1994 Sch 9 Group 1).
Fortyseven Park Street sold ‘fractional interests’ in residences at 47 Park Street in Mayfair. In return for a substantial upfront price a purchaser acquired the ability to occupy a residence at the property of a specified category for a maximum number of nights in each year until 31 October 2050 and to access a range of related benefits during that period. These included the option for the purchaser to exchange stays at the property for stays in other properties and to realise rental...
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