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UK FTT (Tax Chamber): No exempt land supply; Sarabande’s taxable serviced studio supplies made direct to artists; HMRC best judgment assessment invalid

Published on: 12 February 2025

Published by a LexisNexis Tax expert
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Sarabande v HMRC [2025] UKFTT 93 (TC)

SB, a registered charity, holds a long lease of a central London property (the Building). Suture Inc Ltd (SIL), SB’s wholly owned subsidiary, is not VAT-registered. In 2018, SB opted for voluntary VAT registration and sought to recover £341,487.31 of VAT incurred on purchasing and refurbishing the Building. The project transformed what had been a warehouse-style area into art studios, gallery space and meeting rooms. SB’s objective was to create a venue to nurture an artists’ community, and it devised a structured support scheme for artists called the ‘Accelerator Programme’. Through this programme, artists were offered curated, subsidised space, comprising studio and exhibition areas together with a bundle of benefits, including use of professional equipment, guidance from sector specialists and hands-on assistance from as well as advice from industry experts and practical support offered by SB within the Building to participants in the scheme on a structured basis throughout...

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