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HMRC v Longridge on the Thames

In HMRC v Longridge on the Thames [2014] UKUT 0504 (11 November 2014) the UT found that a building was used for a relevant charitable purpose even though recipients of the services provided in the building partially paid for those services.

Longridge a charity provides a wide range of day and residential courses and activities (principally water-based). The building at the center of the dispute was a training centre.

The issue was whether the building was used ‘solely for a relevant charitable purpose otherwise than in the course or furtherance of a business’. If it was used solely for these purposes the services consisting in its construction which had been supplied to Longridge were zero rated (VATA 1994 Sch 8 group 5).

HMRC’s main contention was that the FTT had erred in law by focusing on the price charged by Longridge which in most...

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