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HMRC internal manual

VAT Land and Property

HM Revenue & Customs
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Option to tax - anti-avoidance test: what is the meaning of 'eligible purposes'?: introduction

For someone to be in occupation of a building for eligible purposes, they must be occupying it ‘wholly’ or ‘substantially wholly’ for making taxable supplies, or other supplies which entitle them to credit for their input tax (paragraphs 15(2)(b) and 16(3) of Schedule 10, VATA94).