Edinburgh VAT Tribunal 19 August 1988. Identical appeals against VAT assessments by two companies (A) who carried on the business of letting residential caravans to homeless persons in return for rent . VAT was charged in respect of rent received. The point at issue in each case was whether the letting of the caravans should be zero-rated or exempt, supplies. The rents were paid direct to A by the DHSS; there were no written tenancy agreements and there was no security of tenure . The tenants enjoyed exclusive occupation of the caravans, but not of the surrounding ground, except to make gardens. The caravans had fixed supplies of water and electricity, fixed drainage and sewage and permanent toilets. Although they had wheels, the caravans were supported by wooden blocks. A contended that the supply was zero-rated. The Commissioners argued that the provision of accommodation was a licence to occupy land but conceded that zero-rating overrides exemption where a supply could fall within