Single composite supply of football pitches and league administration

The taxpayer organised five-a-side football and netball league matches. It hired pitches from schools and local authorities which it made available to the teams who have signed up to the league.

It claimed that 87.5% of fees received from participating teams was exempt from VAT on the basis that it offered the hire of a sporting facility under the regular lettings rules (VATA 1994 Sch 9 group 1 note 16). The remaining 12.5% related to the services of organising fixtures and providing referees and bibs for the matches.

The taxpayer submitted a claim for overpaid output tax up to October 2016. HMRC later assessed it to output tax on later returns covering periods up to October 2019. HMRC’s view was that the taxpayer was supplying a standard rated service of ‘organisation of football and netball leagues’.

Allowing the taxpayer’s appeal the First-tier Tribunal held that the services made up a...