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HMRC internal manual

VAT Construction

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HM Revenue & Customs
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Alterations and repair or maintenance - case law and agreements: fences, railings and boundary walls

The construction of, or works to, fences, railings and walls do not qualify as ‘approved alterations’ as the works are not to the fabric of the building.

In Reginald David Bunn (VTD 1467): Erection of a wooden fence in the garden of a house. The Tribunal held that it was not an alteration.

In R G Powell t/a Anwick Agricultural Engineers (VTD 14520): A church had railings erected to control entry to its grounds. The railings were not fixed to the church at any point. On the northern side of the site the railings were fixed on the top of a church wall, which touched the church. The Tribunal held that it was an approved alteration, but must be considered doubtful in light of the High Court decision in AC Tinsley (VCONST08260). On the southern side the railings were freestanding.

In C Mason (VTD 16250): The owner of a listed cottage constructed two sections of brick wall divided by a hedge. One section abutted the cottage. To allow for movement, it was not tied into the cottage. The Tribunal held that it was an approved alteration, but must be considered doubtful in light of the High Court decision in AC Tinsley (VCONST08260).