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HMRC internal manual

VAT Construction

Zero-rating major interest grants in buildings: holiday homes: use ‘for the whole of the year’

The statutory basis for the first test at VCONST03420, which comes from Note 13(i) and the first limb of Note 13(ii), is based on entitlement to reside in the building ‘throughout the year’.

In Loch Tay Highland Lodges Limited (VTD 18785) the appellant argued that the word ‘throughout’ in Note 13 did not mean 365 days of the year. The Tribunal disagreed. They stated:

‘Throughout’ means residence for the whole of the year, if a lesser period or periods were intended, the word ‘during’ would have been used instead of ‘throughout’