More fun than care

Were supplies of child welfare services or sports based activities?

The taxpayer ran children’s day camps at school sites during school holidays. They provided a range of sporting dance and other activities for the children. The staff were mainly sports coaches under the supervision of a separate camp manager.

The company had been VAT registered as an activity sports club in 2010 but new owners decided in 2012 that this was incorrect and applied for deregistration back to 2010 on the basis that the company did not make any taxable supplies. The company offered childcare for working parents and the wide range of activities on offer was necessary. Parents expected their children to be ‘stimulated and/or educated while being cared for in a safe and secure environment’. As such this was an exempt composite supply of care and protection.

HMRC agreed that the services linked to children aged...