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HMRC v UK Storage Company (SW) Ltd

In HMRC v UK Storage Company (SW) Ltd (Upper Tribunal – 17 October) a company (U) provided storage facilities in the form of steel units in a secure compound at a site in Somerset. HMRC issued a ruling that U was required to account for VAT on its receipts. U appealed contending that it was supplying a licence to occupy land. The Upper Tribunal rejected this contention and upheld HMRC’s ruling declining to follow the First-tier Tribunal decision in D Finnamore (t/a Hanbridge Storage Services) v HMRC [2011] UKFTT 216 (TC); [2011] SFTD 551 TC01081 (which the company had cited as an authority). Judge Sinfield held that U was making a single supply of storage services rather than a licence to occupy land. 


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