Final decision on the VAT Optimiser?

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The Upper Tier Tribunal has released its decision in the AN Checker Heating & Service Engineers case. This was the test case for the VAT Optimiser system used by many plumbers and heating engineers. The software applied a cost-based apportionment to a single supply of a central heating system. It calculated VAT at 5% on part of the supply and 20% on the balance.

HMRC consistently argued that the supply was not capable of being apportioned in this way, as it was a single supply at the standard rate. The Upper Tier considered some ECJ decisions addressing caravans and their contents, portable barbeques and their fuel, and supplies of funeral services.

The decision runs through the history of the reduced rate for energy-saving materials.

The Upper Tier found little in the taxpayer’s argument of any merit.

You can read the decision here:

About Les Howard


Hi, I am a VAT Consultant, working mainly with charities. I am based in Cambridgeshire

I have over 20 years experience in VAT, and am currently also a part-time member of the Tax Tribunals.


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