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HMRC internal manual

VAT Land and Property

Taxable person: land and buildings owned by more than one person: does the benefit accrue to the trustees or the beneficiaries?

There is an inherent difficulty where trust property is concerned, which is that the trustee has the legal interest in that property whilst the beneficiary has the beneficial interest.

Where the property is sold, let or otherwise dealt with, it will normally be the case that the beneficial owner will be seen as the person making the supply.