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HMRC internal manual

VAT Construction

Building materials - Note 22 and Note 23: furniture: cupboards, wardrobes, and so on

Cupboards and wardrobes are generally formed in one of three ways, namely by:

  • fitting a prefabricated modular carcass system into an available space. Normally the ‘wasted’ space surrounding the carcass will be masked off with trim panels
  • fitting out an available space with components that are largely unique to that installation (these are often shaped on site)


  • enclosing an available space without fitting it out.

The first two methods always result in furniture that (other than for kitchen furniture) is excluded from being ‘building materials’. The third does not.

The borderline between the last method and the previous two is explained in Notice 708 Buildings and construction. This borderline means that items listed below are ‘building materials’ and should feature no more than ‘basic storage facility’, which are formed by becoming part of the fabric of the building:

  • airing cupboards
  • under stair storage cupboards
  • cloaks/vestibule cupboards
  • larders, closets and the like.

Examples of installations that are not ‘building materials’ can be found in:

  • McLean Homes Midlands Ltd ([1993] STC 335)
  • Stuart Henry Wade (VTD 13164) 
  • Simon Leon t/a Custom Bedrooms (VTD 13200) 
  • Moores Furniture Group Ltd (VTD 15044).

In the early decision in Harrington Construction Ltd (VTD 3470), the internal fitting out of the wardrobe consisted of a single shelf with hanging rail beneath. The Tribunal decided that the installation was not fitted furniture, and this has been accepted ever since.

However, no other forms of fitting out should be accepted. As has been shown in the decision in Moores Furniture Group Ltd (VTD 15044), where the Tribunal stated:

…the addition of [a raised floor] materially alters the impression of the unit which would be given to the onlooker opening the doors. He would not merely see a part of the room divided off but would perceive something much more akin to a piece of designed furniture.