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HMRC internal manual

VAT Land and Property

Exemption: licences to occupy land: why ‘licences to occupy’ are included in the UK land exemption

The European concept of a ‘leasing or letting of immovable property’ is wider than the UK land law concept of leases and lets.

To ensure that all ‘leasing or letting of immovable property’ potentially falls within the scope of the UK land exemption, the UK exempts ‘licences to occupy’ in addition to formal interests in land.