Wedding VAT

The owner of Drumtochty Castle granted the appellant a licence to operate its business from the castle.

The business involved using the venue for marriage services and receptions as well occasional conferences and corporate dinners.

Guests could stay overnight and take part in activities such as fishing clay pigeon shooting cycling and archery.

The appellant provided the facilities but not the catering although it did recommend caterers with whom it worked frequently.

A dispute arose over the VAT chargeable.

HMRC said the issue was whether the supply was one of composite wedding services or whether there was a supply of an interest in land for a fee.

The main activity was the supply of services in relation to the use of the castle as a prestige wedding venue for which the appellant charged a substantial facility fee.

Clients were supplied with a package of services...