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HMRC internal manual

VAT Construction

Zero-rating the ‘approved alteration’ of a ‘protected building’: is the work ‘approved’: has consent been granted

Works that are not covered by the terms of a listed building consent are not ‘approved alterations’. The Tribunal has repeatedly supported this view, examples being:

  • John Hollier (VTD 3758)
  • N Brice (VTD 6376)
  • Dr David Thomas Haigh (VTD 20934)

The listed building consent must have been granted when the relevant works are carried out, rather than when the time of supply takes place (such as when an invoice is issued or payment made). The Tribunal has supported this view in P V R Nicholls (VTD 11115).

Late permissions are not retrospective consents; they are only permissions to retain unauthorised works. Works covered by such permissions are not ‘approved alterations’. The Tribunal has supported this view in a number of decisions, an example being Alan Roper & Sons Ltd (VTD 15260).