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HMRC internal manual

VAT Transfer of a going concern

HM Revenue & Customs
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Common areas of difficulty: exception - property in Scotland

The only exception relates to the transfer of a property rental business in Scotland. The disposal of the “ownership” may be seen to be direct from A to C, regardless of the existence in the middle of the transaction of B. HMRC accept that TOGC can apply subject to meeting the other TOGC conditions.

(Further guidance on the transfer of property rental businesses is contained in VTOGC6400 of this guidance and in Notice 700/9).