Honourable Society of the Middle Temple v Revenue and Customs Commissioners [2013] UKUT 0250 (TCC), [2013] All ER (D) 127 (Jun)
Upper Tribunal (Tax and Chancery Chamber), Judge Sinfield and Judge J Gort, 24 May 2013
The provision of accommodation and the supply of water by the Middle Temple constituted a single supply for the purposes of VAT.
Richard Bramwell and Michael Collins for the taxpayer. Raymond Hill for the Revenue and Customs Commissioners.
The taxpayer was one of the four Inns of Court, associations whose members were barristers in England and Wales or studying to become barristers. It held land and buildings in the western part of the Temple in London (the Inn) and most of its buildings were let. The taxpayer had opted to tax its land under para 2 of Sch 10 to the Value Added Tax Act 1994, the effect of which was that the grants of leases in relation to the premises in the Inn were supplies chargeable to VAT at the standard rate.
For historical reasons, the taxpayer owned a network of
