Commentary

V4.234 Major interests—non-residential buildings converted to dwellings or for a relevant residential purpose

Part V4 Exemption, zero-rating and reduced rates

V4.234 Major interests—non-residential buildings converted to dwellings or for a relevant residential purpose

V4.234 Major interests—non-residential buildings converted to dwellings or for a relevant residential purpose

This paragraph examines the zero-rating extended to the first grant of a major interest in certain newly converted buildings under VATA 1994, Sch 8, Group 5, item 1(b).

VATA 1994, Sch 8, Group 5, item 1(b) zero-rates the first grant by a person converting a non-residential building (see V4.232D) or a non-residential part of a building into:

  1.  

    •     a building into a building designed as a dwelling or number of dwellings (see V4.232BA)

  2.  

    •     a building intended for use solely for a relevant residential purpose (see V4.232BB)

of a major interest (see V4.232G) in, or in any part of, the building, dwelling or its site.

The following notes to VATA 1994, Sch 8, Group 5 are relevant to the scope of this relief:

  1.  

    •     VATA 1994, Sch 8, Group 5, note 1 provides for the term 'grant' to include including an assignment or surrender

  2.  

    •     VATA 1994, Sch 8, Group 5, note 2 describes when a building is designed as a dwelling or number of dwelling, for details see V4.232BA

  3.  

    •     VATA 1994, Sch 8, Group 5, note 4 describes when use is for a relevant residential purpose, for details see V4.232BB

  4.  

    •     VATA 1994, Sch 8, Group 5, note 7 describes when a building or part of a building is 'non-residential' prior to conversion, for details see V4.232D

  5.  

    •     VATA 1994, Sch 8, Group 5, note 9 provides that the conversion, other than to a building designed for

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