Silver Sea Properties (Leamington Spa) SARL v HMRC

In Silver Sea Properties (Leamington Spa) SARL v HMRC [2021] UKFTT 350 (TC) (7 September 2021) the FTT held (a) that VAT recovery was blocked in relation to the cost of certain goods installed in a new care home and (b) that output tax was due on goods supplied with but not installed in the care home. Article 6 of SI 1992/322 blocked VAT recovery in relation to the installed goods that were not building materials and output tax was due on the goods that were not installed because they were not part of a single composite supply of a zero-rated care home.

The background was the grant of a 25-year lease of a new care home to a care home operator. It was common ground that the grant of the lease qualified for the zero rate of VAT under VATA 1994 Sch 8 Group 5...

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