The demise of the Lord Fisher tests

VAT enthusiasts – and a few non-enthusiasts – will be familiar with the phrase ‘the Lord Fisher tests’. The tests have been as important in the world of the nation’s favourite tax for the last 30 years as a permanent wifi-connection is to anyone aged under 35. But the VAT days of Lord Fisher are at an end because HMRC has replaced the six business tests associated with his name with two completely new tests from 1 June 2022. Is six down to two an example of tax simplification? I hope so.

Lord Fisher case

Lord Fisher organised group shooting events on his estate and charged a fee to his friends and relatives the purpose of the fee being to cover the costs of the day. HMRC – or Customs and Excise in those days – decided that the fees were subject to VAT as ‘business supplies’ but...