Reduced rate for ‘Solid Roof System’?

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A building contractor installed the ‘Solid Roof System,’ a system for insulating conservatories, which involved the supply of a tiled roof. HMRC had challenged the view that the product should be reduced rated as the installation of energy saving materials.

The Tribunal discussed the question of single or multiple supplies, and asked whether one element of the installation was ancillary to another. It concluded (para 159) that there was single supply of insulation materials.

The Tribunal also considered the Upper Tier decision in Pinevale which sought to distinguish a roof from roofing panels. In Pinevale, reduced rating only applied to the insulation materials which were part of a roof, not the roof itself.

The FTT concluded that, since there was a single supply, and that supply included as a main aim insulation, the whole supply must be a reduced rated supply. I suspect HMRC may consider this decision has broadened the scope of the reduced rate too wide, and may seek to Appeal it.

The decision is here:

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