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International Antiques and Collectors’ Fairs Ltd (TC4538)
The company organised antiques and collectors’ fairs. Visitors’ admission fees were subject to VAT at the standard rate. Exhibitors’ pitch fees were treated as exempt on the basis that they were exempt supplies of land.
In 2012 HMRC decided that the stallholders were receiving the benefit of a fully organised fair provided by the company. This included security advertising electricity and supervision at the venue. The land benefit was incidental and would be of no value without the company organising the antiques fair. HMRC also referred to the company’s accounts which described its activity as “organising conferences and exhibitions and antiques fairs” rather than “the letting of land”. According to HMRC the supply was a standard-rated supply of services.
The taxpayer appealed. It claimed that each contract with an exhibitor for a...
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