This was an appeal by HMRC against a decision of the First-tier Tribunal (FTT) that student accommodation could be zero-rated as a building designed as a dwelling or number of dwellings.
This was an appeal by HM Revenue and Customs (HMRC) (‘the appellant’) against a decision of the FTT that the services relating to the construction of student accommodation made by Summit Electrical Limited (‘Summit’), an electrical subcontractor, to Create Construction Ltd (‘Create’) was zero-rated.
On the basis that a zero-rating certificate had been issued by Create to its supplies and by the developer and on the basis that the buildings were, therefore, to be used for a relevant residential purpose (rather than on the basis that the accommodation created was a series of flats designed as a dwelling), the appellant refused to permit Summit to zero-rate its supplies to Create.
