VAT: withdrawal of concessions for caravan owners: three concessions for caravan owners will be withdrawn with effect from 1 January 2012 because they conflict with EU law.

The concessions currently operate as follows: when VAT is charged by a site owner on a pitch fee, certain recharges made to a caravan owner are not subject to VAT or are subject to VAT at zero rates. This treatment applies to

  • the recharge of business rates, as outside the scope of VAT
  • zero rate water and sewerage charges, where actual consumption cannot be identified
  • first time connection to utilities, as zero rated for VAT.

From 1 January 2012, this concessionary treatment is removed. So, if VAT is due on the pitch fee for the caravan, VAT should also be charged on the recharge of the above items. 

H M Revenue & Customs has recently confirmed in Revenue & Customs Brief 37/11 that the concession will still apply where invoices are raised for rates or water rates prior to 1 January 2012 even if the charges relate to the period after the concession is withdrawn.  However it must be normal practice to raise an invoice at this time.  In the case of connection charges, where the connection is made before 1 January 2012 the concessionary treatment can still be used regardless of when the invoice is raised or payment received.

Small print and links

Source: HMRC Brief 37/11

For further assistance on VAT or any other matter, please contact the Virtual Tax Partner support line.

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