A client owns a property in the UK through an offshore company based in Guernsey. The property has an outbuilding which the offshore company wishes to extend and refurbish. Can the offshore company reclaim VAT on the extension and refurbishments.
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What are they doing with the property
The place of supply of land related services (construction/refurb) is the place the land is. So whoever supplies them will (if registered) charge VAT.
They'd only be able to recover this VAT if they incurred it in the course of their taxable business, since this is to do with property that would likely mean that they'd be making supplies in the UK, and so need to register in the UK in order to recover any VAT (assuming those supplies are taxable and not the normal exempt supplies that you'd make with land).
So basically we need to know; Is the offshore co. UK VAT registered?, Does it make any supplies in the UK?, Is this a commercial or residential building?, what will it use the refurbed building for?, what does it use the current building for?