Damon Wright (K3 Tax Advisory) questions the Upper Tribunal’s ruling on the VAT Tour Operators Margin Scheme.
The facts in HMRC v Sonder Europe Ltd [2025] UKUT 14 (TCC) are as follows. Sonder commenced its UK operations in 2017. During the relevant VAT return periods being considered it supplied accommodation in the UK to corporate and leisure travellers. To do so Sonder leased self-contained apartments from third party landlords for periods between two and ten years. It then granted licenses to ‘travellers’ to occupy the apartments for periods ranging from a single night up to a month. The average stay by a traveller was five nights.
Approximately 37.5% of the apartments Sonder rented were furnished and described as ‘ready to go’. The remaining 62.5% were unfurnished and could not be used in Sonder’s business until Sonder had furnished them to its specification.
The agreements between Sonder and...
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Damon Wright (K3 Tax Advisory) questions the Upper Tribunal’s ruling on the VAT Tour Operators Margin Scheme.
The facts in HMRC v Sonder Europe Ltd [2025] UKUT 14 (TCC) are as follows. Sonder commenced its UK operations in 2017. During the relevant VAT return periods being considered it supplied accommodation in the UK to corporate and leisure travellers. To do so Sonder leased self-contained apartments from third party landlords for periods between two and ten years. It then granted licenses to ‘travellers’ to occupy the apartments for periods ranging from a single night up to a month. The average stay by a traveller was five nights.
Approximately 37.5% of the apartments Sonder rented were furnished and described as ‘ready to go’. The remaining 62.5% were unfurnished and could not be used in Sonder’s business until Sonder had furnished them to its specification.
The agreements between Sonder and...
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