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VAT on residential service charge maintenance: FTT finds supplies to lessors; no land exemption; no disbursements; appeal stayed pending Chelsea Cloisters (Places for People Homes Ltd v HMRC)

Published on: 03 December 2025

Published by a LexisNexis Tax expert
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Places for People Homes Ltd v HMRC [2025] UKFTT 1417 (TC)

The appeal centred on the VAT treatment of supplies delivered by a number of maintenance trust companies (MTCs) in relation to 25 blocks of flats (the ‘properties’). It was common ground that the MTCs bore obligations to maintain the structure and common parts of the properties, and that they made supplies in carrying out those obligations (the ‘maintenance services’). The lessees of the flats within the properties made periodic payments to the MTCs to cover the cost of maintenance services. Each MTC retained a fee for its role, paying the balance into a trust, which it then managed in its capacity as trustee. The costs that each MTC incurred in maintaining the properties were drawn from the trust fund, and included fees charged by the management company, the direct salary costs of staff employed by each MTD and other...

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Date [ date ] Parties [ name of Landlord ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Landlord) [ name of Tenant ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Tenant) [ [ name of Guarantor ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Guarantor) ] [ [ name of Mortgagee ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Mortgagee) ] Definitions Within this Deed, the terms below shall be interpreted as follows: [ Annual Rent • the annual sum reserved under the Lease; ] [ Insurance Rent • the Tenant’s share of the Landlord’s costs of insuring the Property (as set out in the Lease); ] Lease • the lease of the Property dated [ date ], entered into between (1) [ the Landlord OR [ name ...

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