This is an appeal against a decision by HMRC rejecting the appellant’s claim that supplies it made were exempt supplies of land. The substantive issue was how the grant of long leases of what were described as Store Pods was correctly characterised for VAT purposes. HMRC contended that it was a single composite supply of storage facilities taxable at the standard rate.

Background

The appellant purchased the freehold of the building, which it did not opt to tax. Subsequently, the appellant fitted out the building as a