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HMRC internal manual

VAT Construction

Changing the use of certificated buildings - buildings completed before 1 March 2011: when is a building complete?

For the purposes of the change of use provisions a fixed point from which 10 years can be measured is required. This is far more specific than the date that ‘construction is complete’ is for the purposes of meeting the provisions of the Value Added Tax Act 1994, Schedule 8, Group 5 (VCONST02530).

For the purposes of this section, a building is complete when an architect issues a certificate of practical completion in relation to it or it is fully used, whichever happens first.

Where a conversion has taken place, it will be the date that the conversion is completed. There is unlikely to be a certificate of completion. If that is the case, the date to use is the date when the building is first fully used. This is confirmed by the Value Added Tax Act 1994, Schedule 10, Paragraph 39, which imports Schedule 9, Group 1, Note 2.