TGH (Construction) Ltd v Revenue and Customs (VAT - ZERO-RATING : Building work)

VALUE ADDED TAX � zero rating - construction of a garage and workshop � accepted as constructed at the same time as a relevant residential building � whether �used together as a unit solely for relevant residential purposes� � yes � appeal ALLOWED �

Sitting in public at The Old Bakery, 115 Queens Road, Norwich, NG1 3PL on 10 December 2015

This appeal concerns a claim by the Appellant that certain works undertaken by it should properly be subject to Value Added Tax at the zero rate pursuant to section 30 and item 2(a) to Group 5 Schedule 8 Value Added Tax Act 1994 (�VATA�) as a consequence of the application of Note (5).�

The works in question were the construction of a workshop, garage and store (together referred to as the �Workshop�) at the site of The Great Hospital on Bishopsgate in Norwich.

The Appellant is a wholly owned subsidiary of the charity known as The Great Hospital (registered charity number 211953) (�TGH�). TGH was established in 1249 to provide relief for the poor and needy of the City of Norwich.� Pursuant to amended objects the Charity now provides affordable residential accommodation to persons in need who are over the age of 65 in the case of men and 60 in the case of women.