It is correct that, in limited circumstances, materials can be supplied on their own to a charity or disabled person ‘over the counter’ without building services and still be eligible for the zero rate. This is where they are supplied ‘in connection with’ a supply of services which is itself zero rated under VATA1994 Schedule 8, Group 12. The supply to a disabled person of adapting the bathroom in their private residence where this is necessary because of their condition is zero rated under Group 12, item 10. The wording ‘in connection with’ has been interpreted by the VAT tribunal (Gary Flather 11960) to mean that as long as there is a supply of the zero rated services, and the goods are used in this supply, they do not have to have been supplied by the person supplying the services. https://www.gov.uk/hmrc-internal-manuals/vat-relief-for-disabled-people/vrdp11850
This is different to the supply of, for example, building materials in the construction of a new house, where the zero rate applies to the supply of building materials to a person to whom the supplier is also supplying the zero rated building services.
The important factor is that there will be a supply of services by a business, and that the goods will not be fitted on a DIY basis or by a friend or relative for free. To address any potential query raised by HMRC on this point your client should hold confirmation from the installer, such as a statement of works. Notice 701/7 refers to this point in paragraph 6.8. Your client should also keep a copy of the eligibility declaration completed by the customer – a suggested template can be found in Notice 701/7 paragraph 3.6 https://www.gov.uk/guidance/reliefs-from-vat-for-disabled-and-older-people-notice-7017#customer
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