20 May 2020 
Andrea Marshall, Tax Specialist
Martin Scammell has been in touch about a Covid-19-related issue that might affect members either as landlords or as tenants. Most obviously though, it is relevant to retail and similar lettings, where many tenants are asking for a rent holiday, and may be offering something in return for it.
In some of these cases, HMRC have been suggesting that there is a barter transaction, so that a landlord who has opted to tax still needs to account for VAT on the rent that would have been paid, and so that the tenant is potentially making a supply to the landlord. But it also seems that HMRC are being inconsistent about this, and that their analysis is not always correct.
The property sector is trying to clarify the position with HMRC, specifically in relation to the following arrangements:
Martin will let us know of anything that comes of the discussions with HMRC, but in the meantime would be pleased to hear from members who have encountered any other arrangements, or who have had their own discussions with HMRC. Please mail him at martinscammell1@gmail.com, or via Andrea if you would prefer to remain anonymous. Thank you in advance for any input you can give.
