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HMRC internal manual

VAT Government and Public Bodies

From
HM Revenue & Customs
Updated
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Government departments and health authorities: Contracted Out Services (COS) Headings: Examples of items that are eligible for recovery under COS Headings 35 and 37

Please note that this list is not exhaustive. If you are uncertain whether or not the works undertaken is eligible for VAT recovery please seek advice from HMRC.

Alarms

DESCRIPTION RECOVERY COS HEADING
Repairing existing fire/burglar alarms Yes 35
Installation of fire/burglar alarms No  
Extension to current systems No  
Repair by partial replacement of parts within existing fire/burglar alarm Yes 35
The complete replacement of an existing system No  

Asbestos

DESCRIPTION RECOVERY COS HEADING
Removing asbestos Yes 35
Sealing in asbestos Yes 35

Ceilings

DESCRIPTION RECOVERY COS HEADING
Repairing existing ceiling/suspended ceiling Yes 35
Replacing existing damaged tiles in same location (within existing grids structure) Yes 35
Forming fire breaks in ceiling voids No  
Construction/installation of new ceilings/suspended ceilings No  
Complete replacement of suspended ceiling structure No  

Cleaning

DESCRIPTION RECOVERY COS HEADING
Contract cleaning Yes 35

Construction

DESCRIPTION RECOVERY COS HEADING
Building new cool room No  
Construction of a new room No  
Building new extension No  
Major building improvements No  
Installation of a new damp proof course No  
Installation of a silicone based injection No  
Single supply of scaffolding No  
Structural repairs not traditionally performed in-house, as the work requires highly specialised skills No  
Complete replacement of central heating and air conditioning systems No  

Conversions

DESCRIPTION RECOVERY COS HEADING
Converting an office space from small offices to open plan or vice versa No  

Decorating

DESCRIPTION RECOVERY COS HEADING
Repainting and decorating existing walls, windows etc to restore decorative order Yes 35
Re-painting existing external structure Yes 35
First time decoration No  
Resealing against damp and draughts Yes 35

Doors

DESCRIPTION RECOVERY COS HEADING
Fitting fire doors in corridors to form a fire break No  
Widening doors to allow wheelchair access No  
Blocking up old/existing doorways No  
Installing new doors/door frames where none existed previously No  
Installation of automatic/electric doors No  
First time fitting of fire doors in new buildings/ extensions No  
Fitting fire doors in new partitions No  
Repairing by replacing existing doors/fire doors/ door frames (see Note) Yes 35
Replacing existing doors with fire doors (see Note) Yes 35

Note: Exceptions to normal COS rules, where HMRC accept the concept of repair by replacement for the listed items only.

Electrical

Electrical works would include items such as installation of luminaries, general lighting, small power, nurse call systems, electrical connections to other systems.  VAT recovery will be dependent upon the context of the specific job being undertaken - for example, if purely refurbishment, more scope expected for VAT recovery. If major alteration/reconfiguration, limited scope for recovery.

DESCRIPTION RECOVERY COS HEADING
Extension of wiring into new areas No  
Installation of new emergency lighting/fire signs No  
Installation/replacement of Building Management System No  
Installing new/additional wiring and/or sockets No  
Installing new/additional wiring and/or light fittings No  
Installing new/addition cables/wiring for telephone/data lines No  
Complete removal and replacement of wiring back to distribution boards No  
Repair by replacing existing wiring/cabling, individual sockets and light fittings, if in exactly the same location (see Note) Yes 35
Portable Appliance Testing (PAT) Yes 37

Note: Exceptions to normal COS rules, where HMRC accept the concept of repair by replacement for the listed items only.

Equipment/parts

DESCRIPTION RECOVERY COS HEADING
Sterilisation of instruments and equipment Yes 37
Spare parts which are provided as part of the eligible repair and maintenance services Yes 37
Maintenance of security equipment Yes 37

Fire Escapes

DESCRIPTION RECOVERY COS HEADING
Replacing fire escapes No  
Repairing fire escapes Yes 35
Building new fire escapes No  

Flooring

DESCRIPTION RECOVERY COS HEADING
Breaking up existing concrete floors and subsequent relaying at a slight different floor level Yes 35
Repairing existing stuck down flooring by rescreeding and resurfacing bonded fitted flooring, including stuck down carpet, carpet tiles, floor tiles and vinyl Yes 35
Replacing worn flooring with the same type of covering, such as replacing carpet with carpet, linoleum with linoleum, and so on Yes 35
Supplying first time flooring No  
Installing plywood base to level floor No  
Upgrading worn floor covering, for example replacing linoleum with carpet, or replacing carpet with wooden flooring No  

Grounds

DESCRIPTION RECOVERY COS HEADING
Maintenance of grounds and gardens adjacent buildings Yes 35
Gardening Yes 35
Grass cutting Yes 35
Tree surgery Yes 35
Landscaping/redesigning grounds No  

Incinerators

DESCRIPTION RECOVERY COS HEADING
Repair of incinerator Yes 37
Installing new incinerator No  
Construction/extending height of chimney No  
Replacement of incinerators No  
Increasing thickness of existing lagging on incinerators No  

Insulation

DESCRIPTION RECOVERY COS HEADING
First time installing of insulation No  
Installing sound proofing panels No  
Repair by replacing lagging Yes 35

Kitchen

DESCRIPTION RECOVERY COS HEADING
Repair by resurfacing existing worktops and units Yes 35
Installing/building new kitchen units, cupboards, and so on No  
Installing/building new work tops No  
Repair by replacing existing kitchen units, cupboards etc within kitchens/tea points (see Note) Yes 35

Note: Exceptions to normal COS rules, where HMRC accept the concept of repair by replacement for the listed items only.

Lifts

DESCRIPTION RECOVERY COS HEADING
Repairs to existing lifts Yes 37
Replacement of lift No  
Installing a new lift No  

Mechanical

Mechanical works would include items such as pipe work, ductwork, heating units, chiller units, chilled water plant, air handling units, hot and cold water plant, compressed air systems, medical gases and soil and waste pipe work.

DESCRIPTION RECOVERY COS HEADING
Repairs to faulty systems (including parts) Yes 37
Replacement of system No  
Installation of new system No  
Alterations/additions and extensions to existing system No  
Fixing valves and/or meters to existing/new radiators, pipes and taps to regulate temperate of hot water for patient safety/energy conservation purposes Yes 37
Repair existing pipes/radiators Yes 37
Installation of new/addition pipes/radiators No  
Replacing water tanks No  
Building/installing new water tanks No  
First time installation of boiler No  
Replacement of boiler No  
Repair to boiler (including parts) Yes 37
Complete replacement of central heating system No  
Installation of new central heating system No  
Testing and Commissioning No  
Repairing by replacing existing pipes/radiators in same location (see Note) Yes 35

Note: Exceptions to normal COS rules, where HMRC accept the concept of repair by replacement for the listed items only.

Miscellaneous

DESCRIPTION RECOVERY COS HEADING
Minor works of a repair and maintenance nature Yes 35
Disturbance works, where those works only need to be undertaken as a result of alterations to a building or as a result of new building works No  
Fitting of fire hoses/extinguishers No  
Fitting of grilles, bars, locks, window film and security cameras No  
Installation of shelves No  
Replacement of shelves No  
Manufacturers warranties which are included in the purchase price of the goods, this is a single supply of goods No  
Maintenance contracts entered into after the manufacturer’s warranty expires Yes 37

Ramps

DESCRIPTION RECOVERY COS HEADING
Repair existing ramps/handrails for access for the disabled Yes 35
Replacing/altering of ramps/handrails No  
Initial provision of ramps/handrails including replacement of stairs/steps by ramps No  

Roads

DESCRIPTION RECOVERY COS HEADING
Breaking up and removal of covers to existing manholes and their re-provision in the same place at a higher level Yes 35
Resurfacing existing non-fee paying car parks Yes 35
Resurfacing existing footpaths Yes 35
Relaying down to foundation of existing footpaths No  
Road cleaning Yes 35
Building new car park/footpath where one did not previously exist No  

Roofs

DESCRIPTION RECOVERY COS HEADING
Maintenance of roofs including necessary access works Yes 35
Resurfacing/replacing/re-slating existing roof Yes 35
Re-felting of flat roofs Yes 35
Altering existing pitch - that is, replacing flat roof by pitch No  
Roofing over previous open space No  
Installation of canopy No  

Sanitary ware

DESCRIPTION RECOVERY COS HEADING
Repair of existing damaged washbasins and sanitary ware Yes 35
Fitting new washbasins and sanitary ware No  
Replacing existing systems in new locations or replacing bath by shower, toilet by wash basin, and so on No  
Replacement of sanitary back and side panels, vanity units, shower cubicles No  
Replacement of existing damaged washbasins and sanitary ware in exactly the same place, - that is, toilet cistern by toilet cistern, sink by sink, bath by bath. This would not include replacement of sluices and hoppers (see Note) Yes 35

Note: Exceptions to normal COS rules, where HMRC accept the concept of repair by replacement for the listed items only.

Signs

DESCRIPTION RECOVERY COS HEADING
Repairs to existing signs Yes 37
Repair by replacement signs No  
New signs necessary only as a result of a Trust merger Yes 37

Walls

DESCRIPTION RECOVERY COS HEADING
Repairing existing partitions Yes 35
Restoration of damaged plaster work/brick work Yes 35
Constructing new partitions/walls, altering partition layout No  
First time fitting of partitions in new buildings/extensions No  
Painting new walls/partitions No  
Repairing damaged tiles Yes 35
Tiling new areas No  
Repairs to wall-cladding Yes 35
Provision of wall-cladding/wall panels/wall protection rails No  
Replacement wall-cladding/wall panels/wall protection rails No  

Windows

DESCRIPTION RECOVERY COS HEADING
Window cleaning Yes 35
Repairing existing window frames and glass with similar items Yes 35
Bricking up windows or forming new window/window frames No  
Installation of fitted blinds, curtains and curtain tracks No  
Replacement of fitted blinds, curtains and curtain tracks No  
Installation of combination window/blind units No  
Repair to fitted blinds, curtains and curtain tracks Yes 37
Replacement of windows within same aperture (see Note) Yes 35

Note: Exceptions to normal COS rules, where HMRC accept the concept of repair by replacement for the listed items only.

Woodwork

DESCRIPTION RECOVERY COS HEADING
Repairs to dado / picture rail and skirting boards Yes 35
Replacement of dado / picture rail and skirting boards No  

X-rays

DESCRIPTION RECOVERY COS HEADING
Replacement of an X-ray tube or CT Tube (see Note) Yes 37

Note: Exceptions to normal COS rules, where HMRC accept the concept of repair by replacement for the listed items only