This month’s review by Bryn Reynolds and Gary Barnett (Simmons & Simmons) covers three cases ranging from the FTT to the CJEU.
Land exemption and self-storage facilities
In Harley Scott Commercial Ltd v HMRC [2021] UKFTT 368 the FTT held that the grant of long leases over ‘store pods’ in a building amounted to an exempt supply of land. Since the arrangements involved the on-letting of the store pods to end users the supply to the lessors did not amount to a taxable supply of self-storage. In addition the store pods were clearly part of the building and as such immovable property.
HSC owned the freehold of a building which it fitted out as self-storage facilities with store pods built of metal with doors which were fixed to the floor and ceilings. HSC offered 999 year leases of specific store pods at a specific location in the...
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This month’s review by Bryn Reynolds and Gary Barnett (Simmons & Simmons) covers three cases ranging from the FTT to the CJEU.
Land exemption and self-storage facilities
In Harley Scott Commercial Ltd v HMRC [2021] UKFTT 368 the FTT held that the grant of long leases over ‘store pods’ in a building amounted to an exempt supply of land. Since the arrangements involved the on-letting of the store pods to end users the supply to the lessors did not amount to a taxable supply of self-storage. In addition the store pods were clearly part of the building and as such immovable property.
HSC owned the freehold of a building which it fitted out as self-storage facilities with store pods built of metal with doors which were fixed to the floor and ceilings. HSC offered 999 year leases of specific store pods at a specific location in the...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
