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HMRC internal manual

VAT Land and Property

Option to tax anti-avoidance - funding and financing: other payments or transfers from tenant to owner - funding or not?: other types of non-monetary assistance

If a person provides the owner of the land with significant non-monetary help, such as provision of staff, accommodation or equipment, this may be sufficient for that person to be deemed to be the financier of the development.

An example of this would be if the exempt tenant provides the development team or contractors to the project in entirety or to a significant extent.