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HMRC internal manual

VAT Construction

Alterations and repair or maintenance - case law and agreements: structural and internal walls

Works to walls are normally repair and maintenance and are therefore standard rated.

The Governors of St Mary’s College (VTD 1413): Works were carried out to deteriorating reinforced concrete columns, comprising cleaning the corroded reinforcement and restoring the columns to their original dimensions. The Tribunal held it was repair or maintenance.

Linda Courts Residents Association (VTD 1729): Rendering was carried out to a building in order to improve its appearance. The Tribunal held it was an alteration.

Dr N D F Browne (VTD 11388): A front wall was rebuilt employing modern methods. The Tribunal held it was repair or maintenance. They stated:

Alteration there may have been - it is difficult for repair and maintenance not to involve some element of alteration - but it was not alteration for the sake of alteration or for any reason apart from the more effective repair and maintenance of the building. If the most effective way to repair or maintain a building is by employing modern methods which involve the use of different building materials, the alteration so involved does not prevent the work from essentially being essentially a work of repair or maintenance and therefore not eligible for zero rating.

Logmoor Limited (VTD 14733): External walls were rebuilt with new materials in order to incorporate a hayloft and stables into the accommodation of the house. The Tribunal held it was an approved alteration.