HM Revenue and Customs Brief 08/14
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Issued 17 February 2014
VAT: Change of HM Revenue & Customs (HMRC) policy
following the decision in the case of Goals Soccer Centres plc. 
UKFTT 576 (TC)
This brief announces a change in HMRC policy following the
First Tier Tribunal (FTT) decision in the case of Goals
Soccer Centres plc. This applies to all organisers of
sports leagues and competitions in circumstances where pitches and
league/competition management services are being supplied.
Who needs to read this?
Providers of pitches, both indoor and outdoor, used for league
and cup competitions including traders who obtain pitches and
associated facilities from third parties (such as local authorities,
schools, sports clubs) and who administer/manage competitive sports
leagues and competitions.
Goals Soccer Centres plc owned a sports centre with a number
of five-a-side football pitches. It organised and administered
competitive football leagues and competitions and charged the teams
that participated. The business took the view that, for VAT purposes,
this charge was for an exempt supply of land. HMRC disagreed and argued
that the charge was for a taxable supply of the right to participate in
an organised football league.
Decision of the FTT
The FTT found that there were two separate supplies being made:
- a supply of land (the pitches) which was exempt as the
relevant conditions were met, and
- a supply of administration and management services which
was standard rated.
HMRC accepts that the decision of the FTT is applicable to all
traders who operate in circumstances akin to Goals Soccer Centres plc.
This includes traders who hire the pitches from third parties such as
local authorities, schools and clubs. However, exemption will only
apply where there is a series of lets in accordance with the conditions
set out in Note 16, Group 1, Schedule 9 of the VAT Act 1994. More
details are provided in Chapter 5, VAT Notice 742 - Land and Property.
Accounting for VAT
Where a single price is charged to the customer, businesses
will need to determine the value of the two different supplies to
establish the correct amount of VAT due. Whatever method is adopted to
do this, there must be sufficient documentary evidence kept to show how
a business has arrived at a fair and reasonable apportionment.
Paragraph 8.1 of the VAT Notice 700 - The VAT Guide gives more
information. The business will also need to consider how much of the
VAT it incurs is deductible, see Chapter 3, VAT Notice 706 - Partial
What is being published?
Updated guidance on sports leagues to reflect HMRC change in
policy, see VATLP19600. This Business Brief now cancels Business Brief
About the Author
© Crown Copyright 2014.
A licence is needed to reproduce this article and has been republished
for educational / informational purposes only. Article reproduced by
permission of HM Revenue & Customs.
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Article Published/Sorted/Amended on Scopulus 2014-03-04 12:24:28 in Tax Articles