HMRC internal manual

VAT Construction

VCONST02220 - Zero-rating the construction of buildings: is a building being constructed: meaning of ‘building’

It is important that what is constructed is a building and not some other structure. It will usually be clear that a building is being constructed, but there may be instances, particularly involving work carried out for a charity, where this may not be so.

The word ‘building’ is not defined in the legislation. In the absence of a definition, the word should be given its natural meaning. This means a building is a structure fixed to the ground that at its basic consists of walls (or, an alternative, such as an arrangement of columns) supporting a roof that encloses a volume of space.

Other characteristics are that it is of sufficient scale for human occupation and made of durable materials such as brick, timber, and so on.

Examples of buildings are houses, residential care homes and village halls.

Structures that do not exhibit the characteristics of a building, such as bridges or boats, are not buildings.

In Dr John Parkinson (VTD 17257), it was held that a houseboat is not a building.

A similar approach was taken in Upper Don Walk Trust (VTD 19476) which held that a bridge was not a building. Despite the suggestion in Upper Don Walk Trust that a building may not have a roof, we maintain that only structures with roofs can be buildings.