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Sarabande v HMRC

Input VAT recovery on supply of land.

In Sarabande v HMRC [2025] UKFTT 93 (TC) (30 January) the FTT decided that Sarabande (‘SB’) did not make an exempt supply of land to its subsidiary and therefore HMRC’s denial of input tax incurred on acquiring and refurbishing a property was invalid.  

SB is registered charity and the owner of a long leasehold in a property in central London. Suture Inc Ltd (‘SIL’) is a wholly owned subsidiary of SB and not registered for VAT.  

SB applied for voluntary VAT registration in 2018 and sought to claim VAT of £341k relating to the acquisition and refurbishment of the building. The work converted the building from a warehouse-type space into art studios exhibition space and meeting rooms.  

The aim was to have a space for SB to build a community of artists and SB designed a structured programme of...

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