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HMRC internal manual

VAT Land and Property

Exemption: licences to occupy land: difficulties in establishing whether there is a licence to occupy

Licences to occupy are less formal than leases and there will not always be a written agreement. Agreements that purport to be licences to occupy should not be taken at face value.

To consider whether there is a licence to occupy, it is particularly important to establish the facts and to be aware of all the circumstances so you can consider whether all fundamental characteristics of a leasing or letting of immovable property are present.