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HMRC internal manual

VAT Construction

Zero-rating major interest grants after a non-residential conversion: ‘person converting’ a building

In general, the guidance at VCONST03500 applies in the same way to this section as it does to that section.

The only distinction is in relation to the grant of a building where the conversion has not been completed.

When considering whether a person has ‘person constructing’ status, a person has that status when works progress beyond foundation level (VCONST03550). For conversions, real and meaningful works must have been carried out before they have ‘person converting’ status. Judgement should be used to decide whether works are real and meaningful.