This document summarizes a recent Upper Tribunal ruling on the VAT treatment of property conversions that incorporate both residential and non-residential parts. Specifically: 1) The Tribunal ruled that zero-rating is not available for conversions that incorporate both residential and non-residential parts of the original building into new dwellings. 2) In the case, a former pub was converted into four maisonettes, with the lower two incorporating the original non-residential ground floor and the upper two incorporating the original residential floors. 3) The Tribunal agreed with HMRC that this mixed conversion does not qualify for zero-rating, and the sale would instead be exempt from VAT. Developers cannot claim zero-rating where a