HM Revenue and Customs Brief 04/11
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Issued 9 February 2011
This brief confirms HMRC's view of the VAT treatment of
commercially operated sports leagues
It has been issued in response to enquiries from a number of
organisations that run football leagues. The brief reflects what HMRC's
policy has always been. It does not represent a change of policy.
There are a number of commercial organisations that run
football and other sports leagues ('sports league providers').
Typically, a sports league provider will do most or all of the
- organise a league
- allocate fixtures to teams in the league
- provide pitches for teams to play on (some league
providers own pitches, others rent them from other parties)
- provide referees
- determine results
- keep and publish scores and league tables
- award trophies to winning teams
Payments for such supplies are collected in a variety of
ways. For example, the sports league provider may charge a one off
'admin fee' to teams plus a 'match fee' for each game that is played.
Some sports league providers have suggested that they are
making supplies of land of a kind that are exempt under Group 1,
Schedule 9 of the VAT Act 1994 (they rely on Note 16 to Group 1 which
allows a series of lets of sports pitches to be exempt, subject to
certain conditions). They consider that the essential nature of their
supplies is one of pitch hire.
HMRC disagrees with this analysis. We consider that the
supplies made by sports league providers consist of a bundle of
elements, which are integral to each other, but that it cannot be said
that there is one principal element to which all others are ancillary.
In these circumstances, it is necessary to establish the character of
the overarching supply to determine whether it falls within the
exemption. In HMRC's view, the overarching supply is of participation
in a sports league, not a supply of land.
It is therefore HMRC’s view that the supplies made by
commercial sports league providers are liable to the standard rate of
However, supplies made by certain non-profit making bodies
may fall within the Group 10 sports exemption. For details of the
conditions that must be met for the Group 10 exemption to apply, please
see Notice 701/45 Sport.
Claims of misleading advice by HMRC
Some sports league providers have asked HMRC to consider
whether they have been in receipt of misleading advice from HMRC
officers in the past relating to the liability of their supplies. Such
cases must be considered on an individual basis by the appropriate
Complaints Team. We would recommend sports league providers to contact
their Complaints Team if they:
- consider that they have been misled by HMRC in relation to
the liability of their supplies
- have acted in accordance with the misleading representation
- would suffer real detriment if VAT was to be collected for
For information about our complaints procedure, go to
www.hmrc.gov.uk, and under 'quick links', select 'Complaints'.
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© Crown Copyright 2011.
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Article Published/Sorted/Amended on Scopulus 2011-02-11 08:22:29 in Tax Articles