Insulating roofing material did not qualify for the reduced VAT rate – Upper Tribunal decision

The Upper Tier Tribunal has allowed HMRC's appeal against the First-tier Tribunal's decision that conservatory roofs installed by Pinevale Limited qualified for the reduced rate of VAT as “energy-saving materials” amounting to "insulation for roofs".  The product comprised a polycarbonate cellular material in aluminum frames that, when installed, comprised the (insulating) roof of the conservatory and was claimed to provide significant energy savings when compared to other forms of conservatory roofs. When installed, it replaced the conventional roof on a new or existing conservatory.  The First-tier Tribunal decided that this amounted to "insulation for roofs" but the Upper Tribunal disagreed.  The Upper Tribunal preferred a narrower interpretation of the VAT relief and agreed with HMRC's argument that the term "insulation for roofs" did not extend to the roof itself, whatever its insulating qualities.  HMRC's appeal against the First-tier Tribunal decision was therefore allowed.


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