In Pinevale Ltd v HMRC (TC02283 – 9 October) a company (P) supplied polycarbonate panels and radiation strips for conservatory roofs. HMRC issued a ruling that these supplies were standard-rated. P appealed contending that they qualified for the reduced rate under VATA 1994 Sch 7A Group 2. The tribunal accepted this contention and allowed the appeal finding that the products achieved ‘a demonstrable reduction in heat loss’ and holding that they qualified as insulation for roofs within Note 1(a). Sir Stephen Oliver held that Note 1(a) was not restricted to ‘panels to be attached to existing roofs’ but included ‘all types of roofing insulation including those designed for use as a roof or as component parts of a roof’.
Why it matters: VATA 1994 Sch 7A Group 2 provides that the installation of ‘energy-saving materials’ may qualify for the reduced...