VATLP02520 | Supply: Private Finance Initiative (PFI): VAT issues
From HM Revenue & Customs · VAT Land and Property
There are several VAT problems associated with PFI. They are:
the direction of the supply
establishing the nature of the supply in order to determine liability - which can be taxable, exempt or even non-business
timing of supplies
whether there are single or multiple supplies, and
equality of treatment between public and private sector.