Whether a rental premium to be paid by the prospective tenant constitutes the provision of financing depends on the date of the agreement to pay the premium (or, in the absence of prior agreement, the date of the actual payment itself). An agreement to pay a premium entered into before or during construction and which, at that time, will be used by the developer as security or as security for obtaining third-party financing for development, is financing for the development of the land by that person. There may be a number of VAT problems in commercial developments, but in practice most developments do not pose significant problems. It is useful to first consider a simple and problem-free scenario, with speculative evolution. (a) registered persons who, for remuneration, confer on a developer, promoter, contractor, construction undertaking or other registered person development rights in whole or in part in the form of construction services for complex, construction or civil construction projects; and the gross amount invoiced for the provision of taxable services includes any amount received before, during or after the performance of that service for the provision of taxable services and, after examination of section 67 of the Finance Act 1994 reproduced above, it may be found that the service tax must be paid on the gross amount calculated, That is, on the consideration in kind received by the landowners and on the consideration received from potential customers, i.e. on the total gross amount. In the present case, the amount resulting from the consideration received from the owner of the land by the applicant in the form of land rights is included in the value of the villas sold to a potential client, which would mean that the consideration received by the applicant in the form of a development right is considered eligible. The certificate of the chartered accountant recorded in the minutes by the applicant is detailed and attests that the applicant has paid the tax on services on the consideration she received and, in this case, there is no reason to claim again a tax on services on villas built and remitted to landowners. . . .