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HMRC internal manual

VAT Construction

‘Approved alteration’ of a ‘protected building’ (rules prior to 1 October 2012): are the services supplied ‘in the course of’ an ‘approved alteration’

Having established that work constitutes an ‘approved alteration’ it is then necessary to determine the extent that works, not immediately involved with the alteration, might also qualify for the zero rate.

This will include preparatory work before the alteration is carried out and remedial works that are required to make good the area immediately surrounding the alteration. It must be carried out at the same time as the alteration is carried out.

The High Court in Morrison Dunbar and Mecca Ltd ([1979] STC 406) said:

…the right approach is to determine first of all what… alteration work… was done. The services supplied in the course of that work will be zero rated except insofar as the work includes any work of repair or maintenance. The zero rated work will, however, include consequential work, that is, work, whether by way of touching up or repainting or otherwise, which flows directly from the work of… alteration.