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HMRC internal manual

VAT Government and Public Bodies

Police authorities: specific activities: witness protection

The same principles apply to witness protection as covert operations in that transaction details will not be readily available so as not to compromise the operation or the safety of the witnesses (see VATGPB5220). The duty of care the police are obliged to give to witnesses means that it can generally be accepted that hotel accommodation provided for a witness will be of a standard and status of hotel that will attract VAT.

Although the witness will benefit from many of the supplies it is accepted that the expenditure is incurred as part of the non-business activities of the police and so the VAT may be recovered under section 33 (see VATGPB4000).