Acquisition or expenditure for the purpose of disposal


Tainted acquisitions

Tainted expenditure


Availability of relief

Additional periods of deemed only or main residence status

Longer absences

Only or main residence status lacking during last three years of ownership

Period of absence

Bingo promotion profits

Changes in status

Change of occupation

Change of use

Complexity, reasonable excuse for misdeclaration penalty


Construction Industry Scheme 1975-1999

Construction Industry Scheme 1999-2007

Construction operations

Disposals after 9 December 2003

Elections (limited effect of)

Employees (defined)

Employment-related securities (defined)

Founders' shares


Historical background

HMRC and Valuation Office Agency Manuals


Abuse no rights

Change of

Consider law's purpose

EU law overriding UK law: direct effect in member states

Except from VAT narrowly

Fiscal neutrality principle



Means must be proportionate to desired result

Observing principle of effectiveness

Observing principle of territoriality

Payment of VAT only once in respect of same supply

Protecting human rights

Protecting legitimate expectations


Substance trumping form

Sufficient proximity to an illegal activity

Using other documents to interpret ambiguous or unclear material

Mechanism for relief

Occupation under the terms of a settlement

Original scheme of certification and flat rate deduction at source

Parliamentary control

Partial business or investment use

Business use

Residential letting

Period of ownership

Different interests at different times

Husband and wife, successive interests

Non-qualifying tax years

Temporal limitation


References to Acts

Regulations, orders and schemes



Legitimate expectation and legal certainty

Retrospective effect of


Securities (defined)

Statutory instruments, use to change VAT law