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Massey and another trading as Hilden Park Partnership; Hilden Park LLP v CRC, Upper Tribunal (Tax and Chancery Chamber), 28 July 2015
The Hilden Park Partnership which owned and operated a golf club had transferred its business to two companies that were limited by guarantee and prohibited from distributing profits. It had retained the golf course which it let to the two companies along with the driving range changing rooms and health club. In 2005 the partnership was converted into a limited liability partnership.
The taxpayer considered that it was no longer proprietor of the club that the supplies of the right to play golf were made by the companies and claimed it was making exempt supplies of land to the companies. Further the non-profit making companies were making exempt supplies of sport services.
HMRC ruled that the arrangements were an attempt by the taxpayer to avoid VAT on supplies of sporting...
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