Garages - zero-rated or reduced-rated?

[Drellingore]

If one is conducting a conversion that involves erecting a new garage alongside a conversion, do the rules in VAT Notice 708 Section 3 (zero-rating new construction) or Section 7 (reduced-rating conversion) apply?

 

Section 7.6.1 specifically calls out reduced-rating a newly-constructed garage, in the context of a conversion.

 

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You can reduce rate the:

• conversion of an outbuilding into a garage
• construction of a new detached garage
• [...]

This is provided both these conditions are met:

• the garage is intended to be occupied with the ‘single household dwelling’, ‘multiple occupation dwelling’, or the premises intended for use solely for a ‘relevant residential purpose’ resulting from the qualifying conversion
• the work is carried out at the same time as the qualifying conversion

 

 

Section 3.2.1 specifically calls out constructing or converting a new garage when it is constructed or converted at the same time as a dwelling:

 

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The sixth type of qualifying building is constructed when all of the following apply:

• a garage is built, or a building is converted into a garage
• the building is constructed or converted at the same time as, and intended to be occupied with a building ‘designed as a dwelling or number of dwellings’ ― read paragraph 14.2

 

 

If VAT treatment is on a per-building basis, why would anyone choose to go down the reduced-rated route? The conditions in 7.6.1 and 3.2.1 seem completely equivalent to me.