Beta This part of GOV.UK is being rebuilt – find out what beta means

HMRC internal manual

VAT Transfer of a going concern

Land and Property: Property rental business: grant of a lease

The granting of a lease on a building by the freeholder is not a TOGC. The freeholder retains the asset (the freehold) and creates a new asset (the lease). This principle is the same if the head lessee grants a sub-lease.