Zero-rated Construction: Was The Construction Eligible For Zero-rating As A New Build Residential Property?

This is an appeal from the First-tier Tribunal (FTT), which allowed an appeal of the taxpayer against the refusal by HMRC to allow construction work carried on by the appellant to be zero-rated.

The property in question comprised a coach house with some modern flat-roofed extensions. The coach house had been used as a residential dwelling. The plans for its redevelopment involved demolishing the coach house and the extensions save for the northern and western exterior walls and part of the southern exterior wall. A new eastern wall was constructed, together with part of the southern wall, which was built so as to join up with the retained part of the southern wall. Parts of the overall building were increased in height and the footprint of the overall building was increased.

The contention of HMRC