In Lord Harewood (The Harewood Estate) v HMRC (TC01789 – 15 February) the owner of an estate (H) was registered for VAT. He received taxable income from farming hosting concerts and from allowing film and TV companies to use the estate. He also received rental income which was exempt from VAT. The estate included a derelict castle which was a Grade I listed building and was in a dangerous condition. H incurred significant expenditure in stabilising the castle and reclaimed input tax on the work. HMRC issued a ruling that the input tax should be treated as residual and apportioned between taxable and exempt supplies. The Tribunal allowed H’s appeal finding that the work had been undertaken ‘to enable the castle to be used for income-generating activities all of which would be taxable supplies’.
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