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HMRC internal manual

VAT Land and Property

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Option to tax: legislative changes since the option to tax was introduced

Numerous legislative changes have been made since the option to tax was introduced and Schedule 10 is now one of the most complex areas of VAT legislation. Many of the legislative changes were made in response to tax avoidance schemes.

By 2008, Schedule 10 had become very difficult to navigate because of a vast patchwork of amendments. A rewritten version containing a more logical order and simpler legislative style was introduced from 1 June of that year. The rewrite was intended to make the Schedule easier to understand and the bulk of the meaning did not change. However, some changes in meaning were made at that time. These are listed at VATLP26000.