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D Owen, A Owen (TC4469)
The taxpayers were in an agricultural contracting partnership. They charged other farmers for keeping their cattle in eight sheds on their property. The supplies were treated as VAT exempt on the basis that they made an exempt supply of a right to occupy land (VATA 1984 Sch 8 group 1 item 1) and a zero-rated supply of animal feed.
After an assurance visit HMRC decided the supplies should be standard rated on the basis that the supply was one of animal husbandry. The taxpayers provided other services such as provision of feed water and general care. The taxpayers appealed.
The First-tier Tribunal concluded that the services provided by the taxpayers fell short of a full care service. They were responsible for ensuring the cattle were fed and watered but they did not provide...
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