VCONST03550 - Zero-rating major interest grants in buildings: 바카라 사이트˜person constructing a building바카라 사이트™: selling and finishing partially constructed buildings
The sale of a partly constructed building can be a grant by a 바카라 사이트˜person constructing a building바카라 사이트™. This has been confirmed in the case of Stapenhill Developments Limited (VTD 1593), where the Tribunal stated:
We do not consider that item 1바카라 사이트¦ requires a completed building to be upon the land. The operative word is 바카라 사이트˜constructing바카라 사이트™ and not 바카라 사이트˜a person who has constructed바카라 사이트™. The question is nevertheless to be decided as a matter of substance and degree whether or not on the facts of the case what has been done on the land is sufficient to bring the work within the ambit of the expression [바카라 사이트˜person constructing a building바카라 사이트™].
It is accepted that a building is being constructed when work has progressed above foundation level. This is usually when walls begin to be constructed upon the foundations. These walls need not be above ground level. However, simply digging and concreting foundations is not sufficient and in such cases the grant of a major interest in the land is not zero-rated (VCONST03530).
When a partly completed building is sold the purchaser may decide to continue the construction of the building and so become a 바카라 사이트˜person constructing a building바카라 사이트™ in their own right. They will then be able to zero-rate their first major interest grant in the property.