In Ian Owen v HMRC (TC03384 – 5 March 2014) the FTT found that the provision of construction services for the building of a garage abutting a listed building was zero rated.
The tribunal pointed out that the construction of the garage fell within the scope of VATA 1994 Sch 8 Group 6 item 2 as ‘the supply in the course of an approved alteration to a protected building of any services other than the services of an architect…’
HMRC’s view as set out in its guidance manual (VCONST08240) was that in the absence of substantial reconstruction of the house the garage did not fall to be zero rated (as it did not fall within the scope of note 2 to group 6). However the tribunal explained that it was not necessary for note 2 to be satisfied as the building of...
