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HMRC internal manual

VAT Construction

HM Revenue & Customs
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Zero-rating major interest grants in buildings: ‘person constructing a building’: change of legal entity

If an entity changes its name, it does not lose ‘person constructing’ status. This is because the entity is unchanged.

If, however, a ‘body’ is re-structured and becomes a different entity as a result, then the successor can’t inherit ‘person constructing’ status from the body that ceases to exist.

In general, re-structured local authorities on boundary changes, and de-nationalised bodies on privatisation, become different persons and can’t inherit ‘person constructing’ status.

However, please note that following the local government re-organisation in 1996, we misdirected local authorities and allowed ‘person constructing’ status to be transferred following a change in entity. It has been agreed that, with regard to that particular re-organisation, the re-structured local authority can inherit ‘person constructing’ status. This should only be agreed to if it can be established that the transferring body had ‘person constructing’ status in respect of the building.