Single purpose voucher

Treatment of reward payments made by crowdfunding investors

The taxpayer raised £670 000 through a crowdfunding website to fund the cost of a robot drilling 20 metres into the surface of the moon. The aim of the project was to collect data although it would not happen until at least 2024.

Each investor paid £60 in December 2014 in return receiving the promise that they could acquire either physical or digital space in a time capsule to be buried in the moon. HMRC argued that this receipt of money in return for taxable goods or services created a tax point for VAT purposes and the company was liable to VAT registration and to account for output tax. If the money was not a prepayment it would be deemed to be a single purpose voucher – the right to acquire space in the time capsule – on...