Services for an overseas estate agent: is UK VAT charged?
A colleague and myself disagree with the VAT outcome of a supply of services made by my VAT-registered UK-based client for an estate agent in France. My client will go into a UK property – commercial or residential – and measure up the room with his special computer zapping equipment, which also produces high quality digital photographs of the building and its rooms that can be used by the French company for marketing purposes.
My view is that my client is providing a land service – how can it be anything else, because it involves a specific building – so should add 20% VAT to his invoices because the properties are all in the UK. However, my colleague says that the skill of my client is linked to computer/digital services and not land, so the charges to the French company are outside the scope of VAT and subject to the reverse charge in France.
Finally, what would be the position if my client did work for private individuals based outside the UK who might need measurements and photos for their UK homes, ie business-to-consumer supplies?
Query 20,747 – Zapper.
Share and share alike
We have a new client who holds shares in a private limited company that qualify for business property relief (BPR). The shares were acquired in several separate tranches over time, with the result that, at the relevant date, a proportion of the shareholding will have been owned for less than the required two-year qualifying ownership period.
How should the minimum ownership period be determined in these circumstances? Specifically, is there any statutory provision, HMRC guidance, or case law that prescribes how the two-year ownership requirement is applied where shares have been acquired in multiple tranches? In particular, is there any concept of a share pool, or any other identification rules, for the purposes of determining which shares satisfy the two-year ownership requirement for BPR?
Readers’ views would be appreciated.
Query 20,748 – Cher.
Playing the right notes, but not necessarily in the right order
Our clients are three members of a pop band. Unfortunately, after some previous modest success, the band’s recent album was badly received in the music press and the band members each received therapy to cope with the bad publicity.
Each band member has their own personal service company (PSC) and personally owns an equal one-third share of the limited company that the band trades through. Two of the band members invoiced their therapy through the PSC but one invoiced this through the main company.
Is the cost of the therapy tax deductible in the companies and does it create a benefit in kind for the individuals? I’m wondering whether it is exempt as some form of medical treatment. Finally, does the fact that in one case the treatment was charged to the main trading company rather than the individual service companies make any different to the tax analysis?
We’d be grateful for readers’ experience in this area.
Query 20,749 – Dr Phil Good.
Is company outside the scope of UK corporation tax?
Our client is a Norwegian company that owned a property in the UK, which it rented to a tenant. The company submitted a corporation tax return (CT600) for the year ended 31 August 2025. That return included UK bank interest, on which the company paid UK corporation tax.
The company decided to sell the UK property in 2025, and the tenant vacated the property in July 2025, Contracts on the sale of the property were exchanged in early November 2025, and the sale was completed on 7 January 2026.
I have two questions. The first is what accounting period does the gain on the property disposal fall into, given that there was no activity between the property being vacated and its sale?
The second concerns the bank interest, which was paid gross. As I understand it, under Article 11 of the UK–Norway double taxation agreement, the interest should only have been taxable in Norway. Is the company entitled to a refund of the corporation tax it paid on the interest?
Query 20,750 – Norwegian Woods.
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