United KingdomGOV.UK
Zero-rate apportionment needs solely qualifying use
Apportionment for zero-rated construction now requires the identifiable part to be used solely for a qualifying purpose; mixed-use parts fail the test.
By Taxxa AI OyPublished 10 November 2026
Apportionment for zero-rated construction work is appropriate only where an identifiable part of the building is used solely for a qualifying purpose while the rest of the building is not.GOV The added qualifier narrows the previous test, which spoke only of use for a qualifying purpose
GOV: a part in mixed qualifying and non-qualifying use no longer meets the headline test for splitting the supply
GOV. Typical cases are flats constructed together with a new shop, where only the dwellings are zero-rated, and buildings split between charitable non-business use and business use.
Time-shared parts show where the boundary falls. Where part of a building serves a relevant charitable purpose in the morning and other purposes in the afternoon, the building is not used solely for a qualifying purposeGOV, so that part cannot be carved out by apportionment
GOV. Minor amounts of non-qualifying use can still be disregarded.
The reduced rate works differently. Apportionment there is appropriate wherever not only qualifying buildings are being renovated, or not all of the conversions being carried out produce qualifying buildingsGOV — for example a block of flats under renovation where not every flat satisfies the empty-home conditions, or a conversion adding flats where certain floors remain unchanged. Unlike the zero rate, there is no need to identify qualifying and non-qualifying parts
GOV: the parties can agree a fair and reasonable apportionment
GOV.
The statutory footing is Note 10 to Group 5 of Schedule 8 to the VAT Act 1994GOV, which already frames the part-based test in the same terms: a grant or supply relating only to the qualifying part counts as relating to the qualifying building
Legislation, one relating only to the non-qualifying part does not
Legislation, and other mixed supplies are apportioned
Legislation. Note 11 extends that treatment to construction or conversion services supplied partly for other purposes
Legislation, with Note 12 requiring supplies claimed for relevant residential or charitable use to go to a person who intends that use, supported by a certificate for grants
Legislation.
If you are apportioning zero-rated construction work, check each carved-out part is used solely for the qualifying purpose — mixed-use parts no longer qualify.