Earning potential

The taxpayer was a professional association for people who make their living from the business of golf.

It to be approved by HMRC (ITEPA 2003 s 344) for members to be able to claim a deduction for their subscription when calculating their employment income

As well the association involving itself in activities otherwise than for profit its main objects had to be:

• the advancement of knowledge;
• the maintenance of standards; and
• the provision of indemnity or protection to members.

HMRC said that the taxpayer’s activities were carried on for profit and the object of its business was not mainly to maintain standards.

The taxpayer appealed.

The First-tier Tribunal said the fact the association generated “significant income from its assets… or from its provision of services” did not automatically render its activities as a whole as being...