Greenspace (UK) Ltd v The Commissioners for HMRC

Greenspace (UK) Ltd v The Commissioners for HMRC

The supply of roof panels by the Appellant is not a supply of 'insulation for roofs' within the meaning of Note 1(a) to Group 2 of Schedule 7A of the Value Added Tax Act 1994, as the panels serve both as insulation and as a roof covering, and thus fall outside the reduced rate provision.

Parties
Appellant: Greenspace (UK) Ltd; Respondents: The Commissioners for HM Revenue and Customs
Jurisdiction
England and Wales
Judgment Date
10 February 2023
Procedural Posture
Civil Appeal / Court of Appeal Judgment
Outcome
Appeal dismissed
Legal Topics
Value Added Tax, Statutory Interpretation, Energy Saving Materials, VAT Exemptions
Tax Law Value Added Tax Statutory Interpretation Energy Saving Materials VAT Exemptions

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Parties

Greenspace (UK) Ltd

Appellant

The Commissioners for HM Revenue and Customs

Respondents

Procedural Posture

Civil Appeal / Court of Appeal Judgment

Legal Issues

  1. 1 Whether roof panels supplied by the Appellant qualify as 'insulation for roofs' under Note 1(a) to Group 2 of Schedule 7A of the Value Added Tax Act 1994 and are eligible for the reduced rate of VAT

Ratio Decidendi

The supply of roof panels by the Appellant is not a supply of 'insulation for roofs' within the meaning of Note 1(a) to Group 2 of Schedule 7A of the Value Added Tax Act 1994, as the panels serve both as insulation and as a roof covering, and thus fall outside the reduced rate provision.

Court Disposition

Appeal dismissed

Orders

  • The appeal is dismissed; the VAT assessments issued by HMRC stand.