Nominees and input tax

Paragraph 40, Schedule 10, Value Added Tax Act (VATA), provides that a beneficial owner of property is deemed to make any supply that is executed by it through a bare legal owner, and that the input tax relevant to such a supply is input tax of the beneficial owner. 

This generally allows ‘nominee companies’ to be treated as irrelevant to the VAT chain of supply where property interests are involved.

But what happens where the beneficial owner merely occupies property and does not make property supplies, and the lease is in the name of its nominee? Logically, that too should follow suit, since otherwise the terms of paragraph 40 would appear too narrow to fulfil the clear purpose.