VRDP29600 - Motor vehicles [items 2(f) and 2A]: vehicle conversion after the initial supply
A business may supply a standard production vehicle to a disabled person or to an appropriate charity, but with an arrangement to convert the vehicle to meet the criteria under Item 2(f) or Item 2A at a later stage.
If this applies, then only the chargeable conversion is eligible for zero-rating. This is because the title has changed hands, a supply of goods has taken place, and so only adaptation services can be performed.