V16.871 VAT—speculative property developers—input tax
VAT Information Sheet 8/01, December 2001
1.1 What has changed?
Previously Customs expected that developers would attribute input tax to either taxable or exempt supplies, depending on the supplies they intended to make. Although not wrong in itself, this policy did not recognise that there is an earlier stage where developers investigate many potential projects without having a clear intention as to what supplies they will make, where or when.
We would be pleased to receive any comments you may have about this publication. Please write or fax your comments or suggestions to the Partial Exemption Team, Customs and Excise, 4th Floor West, New King's Beam House, 22 Upper Ground, London SE1 9PJ, or fax: 020 7865 4824.
2 Background—attribution and adjustment of input tax
2.1 Attribution of input tax
A taxable person can deduct input tax on goods and services which he uses in making taxable supplies. Partial exemption methods specify how to calculate how much input tax can be deducted. A key stage in a partial exemption method is attribution—
— Input tax on goods and services which are used or will be used wholly in making taxable supplies is attributed to taxable supplies (and can be deducted in full).
— Input tax on goods and services which are used or will be used wholly in making exempt supplies is attributed to exempt supplies (and in principle cannot be deducted).
Other (residual) input tax is apportioned between taxable and exempt supplies as specified in the method.
2.2 Adjustment of