Admission fees to charity fundraising event

The taxpayer - Yorkshire Agricultural Society - organises the annual Great Yorkshire Show which is held for three days in mid-July. It is an important part of the charitable objectives of the society which was both a registered charity and a charitable company limited by guarantee. The taxpayer claimed that the show had two key purposes: to raise funds for the society and to serve as an educational event about the latest developments in farming. The daily attendance could be up to 35 000 people.

Admission fees for 2016 and 2017 were treated as standard rated but the taxpayer submitted a voluntary disclosure in April 2020 for overpaid output tax on the basis that the income qualified for exemption as a fundraising event organised by a charity. It adjusted its input tax to reflect partial exemption but this still produced a net overpayment of VAT.

The publicity...