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HMRC internal manual

VAT Land and Property

Supply: Private Finance Initiative (PFI): assurance action

If you come across a PFI scenario you will need to consider the following:

  • what is the chain of supply?
  • whether there is a single composite supply or separate mixed liability supplies.
  • what liability should apply at each stage of the chain.
  • who initially owned the land - has it been transferred to a special purpose vehicle set up by the PFI provider or has the PFI provider merely provided construction services?
  • to whom is the building/services leased and what is the consideration, and
  • what are the financing arrangements?