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CRC v UK Storage Company, Upper Tribunal (Tax and Chancery Chamber)
The taxpayer company provided storage for private individuals, a service that HMRC decided was liable to standard-rate VAT.
The company said it was providing a licence to occupy land, which was exempt.
The First-tier Tribunal backed the taxpayer’s claimed, holding that the services were exempt supplies of leasing of immovable property. The Revenue appealed.
The Upper Tribunal considered first whether the storage units were immovable property. Based on their objective characteristics, the tribunal judge decided they were capable of being moved and were not immovable property.
He agreed with the taxman that the company was making a single supply of storage of services rather than a licence to occupy land.
HMRC’s appeal was allowed.
