HMRC have traditionally taken the view that where a completed building is transferred as a TOGC
, the buyer cannot obtain "person constructing" status and therefore cannot make the onward zerorated sales.
In cases where the seller retained an interest and granted a subordinate interest to the buyer such as a lease or a sub-lease, HMRC's previous policy was that this did not qualify as a TOGC
and, in cases where an option to tax had been exercised by the seller, VAT was due on the transfer at the standard rate.
The book includes appendices covering: contracts of insurance; Lloyd's VAT arrangements; HMRC ABI partial exemption guidance for the insurance sector; TOGC
legal extracts; guidance on the cost sharing exemption; and the VAT territory of the EU.