NHS Ayrshire v HMRC: VAT Zero-Rating Dispute on Hospital Construction Services Dismissed

• The case involves NHS Ayrshire and Arran Health Board appealing against a decision by HM Revenue and Customs.
• The appeal concerns whether construction services and materials for part of a National Secure Adolescent Inpatient Service building should be zero-rated for VAT.
• The building, named Foxgrove, is located in the grounds of Ayrshire Central Hospital.
• The Appellant argues for partial zero-rating for a section of the building used solely for a Relevant Residential Purpose.
• The Respondents argue that the building is a hospital or similar institution, thus not eligible for zero-rating.
• The Tribunal dismissed the appeal, agreeing with the Respondents.
• The hearing occurred in Glasgow on 12 and 13 December 2024, with the judgment issued on 1 May 2025.
• Tribunal Judge Ruthven Gemmell WS and Tribunal Member Sonia Gable JP presided over the case.
• Martin Kaney represented the Appellant, and Paul Marks represented the Respondents.

Source: bailii.org

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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