Prebends Bridge repairs

Durham Cathedral carried out repairs on the Prebends Bridge. The bridge’s maintenance was the responsibility of the cathedral and the taxpayer argued that the VAT on repairs should be treated as partly business-related. Under an agreement between HMRC and the Churches Main Committee about the percentage split between religious activities and economic activities where costs were not ‘directly or exclusively for either business or non-business activities’ it was agreed that they should be split 35% for non-business and 65% for business.

Under this arrangement the taxpayer agreed that maintenance of the bridge was non-business. But in light of Sveda (C-126/14) [2015] STC 447 which had confirmed that there did not need to be a link between a specific output tax and input the taxpayer claimed that the...