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HMRC internal manual

VAT Transfer of a going concern

Land and Property: Property rental business: general

VTOGC6415, to VTOGC6465 and Notice 700/9 detail various scenarios when the transfer of a property rental business may constitute a TOGC and when it may not. The scale and complexity of property transactions can sometimes obscure what is going on. The Morland case discussed at VTOGC3630 illustrates this point.

In all these cases, even if the transaction is a TOGC, the sale of the property will not be de- supplied unless the option to tax conditions are met.

You are advised to fully read the section on “Transferring a property business as a TOGC” in Public Notice 700/9.