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HMRC internal manual

VAT Transfer of a going concern

Land and Property: Property rental business: sale to the existing tenant

If the freehold in a property is sold to the existing tenant, who currently rents the whole property, the transfer is not a TOGC. The tenant is not using the property to carry on the same property rental business. However, if the purchaser is only one of several existing tenants and the freehold is sold to him with the benefit of the other tenants’ leases, a TOGC of a property rental business can be seen as taking place.