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HMRC v The Honourable Society of Middle Temple

In HMRC v The Honourable Society of Middle Temple (Upper Tribunal – 28 May) trustees of certain land in the City of London leased several properties used as barristers’ chambers to tenants. The trustees had opted to tax the properties. The tenants were supplied with water. In accounting for VAT the trustees treated part of the rent paid by the tenants as attributable to a zero-rated supply of water. HMRC issued a ruling that the trustees were making a single supply of a leased property and that none of the consideration qualified for zero-rating.

The Upper Tribunal upheld HMRC’s ruling (reversing the First-tier decision). Judge Sinfield held that ‘in order not to disturb the functioning of the VAT system account must be taken of the requirement that every transaction must normally be regarded as distinct and independent and a transaction which comprises a single...

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