i found this.....you can read the full article at the web address at the bottom of this post..
Customs bank on the Halifax
by Technical Department at 00:00 23/07/01 (Technical Articles)
Article by Stanley Dencher, Senior Technical Editor, Croner.CCH Group
Ltd, published in the July 2001 issue of Tax Adviser.
Customs are apparently involved with several test cases in the
campaign against VAT avoidance. One such case is Halifax plc No.
17,124.
The Halifax's supplies are generally VAT exempt because it is a bank
(VATA 1994 Sch 9 Grp 5). During the relevant periods, its VAT recovery
rate was under five per cent. For the purpose of its banking business
it needed to construct call centres. If it had directly constructed
the call centres, most of the VAT on the construction costs would have
stuck. However, it used a scheme which involved three other companies
and which used the standard method of calculating a partically exempt
person's recoverable VAT. If the scheme had worked, the Halifax and
the three companies would together have recovered all of such VAT
which amounted to over £5m. Each of the three companies was separately
VAT-registered and was a subsidiary of the Halifax.
CIOT - Customs bank on the Halifax