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HMRC have accepted that the ruling in the VAT case Goals Soccer Centres plc (TC2253) applies to all relevant traders.
HMRC have accepted that the ruling in the VAT case Goals Soccer Centres plc (TC2253) applies to all relevant traders.
The department has issued a change in policy as the result of the 2012 First-tier Tribunal decision in favour of the taxpayer company, the owner of a sports centre with five-a-side football pitches.
The business organised leagues and competitions, charging participating teams a fee that the taxpayer argued was for an exempt supply of land for VAT purposes. The Revenue disagreed, claiming there was a taxable supply of the right to participate in an organised football league.
The First-tier Tribunal found there were two separate supplies: an exempt supply of land, and a standard-rated supply of administration and management services.
The tax authority now accepts that the decision applies to traders including those that hire pitches, both indoor and outdoor, from third parties that operate in circumstances akin to Goals Soccer Centres – but the exemption will apply only where there is a series of lets in accordance with the conditions set out in VATA 1994, Sch 9 group 1 note 16.
Businesses that charge a single price to the customer will need to determine the value of the two different supplies to establish the correct amount of VAT due – and sufficient documentary evidence must be kept to show how a firm has arrived at a fair and reasonable apportionment.
