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HMRC internal manual

VAT Land and Property

Provision of storage facilities (Item 1ka): legislative terms

What is meant by “storage” and “self storage”?

There is no difference between the two terms. Although the law refers to “facilities for self storage of goods” the changes are not restricted to the type of storage where a small area within a dedicated building is rented by an individual to store their own personal property. The law specifies that “the self storage of goods” means -

  • The storage of goods
  • In a relevant structure
  • By either of the following
  1. the person(s) to whom the supply is made; or
  2. a third party with the permission of the person(s) to whom the supply is made.

What is a “relevant structure”?

A “relevant structure” means the whole or part of any of the following:

  • a building
  • a unit
  • a container or other structure that is fully enclosed.

If the storage is within a relevant structure then it is affected by the new rules.

What does “used for the storage of goods” mean?

If goods are physically stored in a relevant structure then the structure is being used for the storage of goods. This is the case regardless of any intention of the supplier of the space or any agreement between the supplier and the customer. A supply of storage may occur regardless of the physical use of a facility if it is implicit in the nature of the premises or commercial documentation that the facility is intended for use as storage and is not actually being used for some other purpose. If the supply is of a facility that is clearly for storage purposes it will be covered by the changes even while it is empty.