Value added tax – Zero-rating. The respective appeals concerned the availability of zero-rating to the first grant of a major interest in a converted property. The Upper Tribunal (Tax and Chancery Chamber) decided that none of the dwellings in either of the appeals had been created by converting part of a building that had not been previously designed for use as a dwelling as required by Item 1(b) of Group 5 of Sch 8 to the Value Added Tax Act 1994 and Note (7) to Group 5, because it had been created from an amalgamation of the non-residential part and the residential part. Consequently, the first appeal was allowed and the second appeal was dismissed.