Harrison v Revenue & Customs [2011] UKFTT 345 (TC) (23 May 2011)

Harrison v Revenue & Customs [2011] UKFTT 345 (TC) (23 May 2011)

The appellant only supplied administration and management services to syndicates, not shooting rights; value of such services did not exceed VAT registration threshold; even if shooting rights were supplied, they were not made in course of a business but for private pleasure and social enjoyment; appellant not liable to register for VAT or pay penalty.

Citation
[2011] UKFTT 345 (TC)
Parties
Appellant: Edward George Harrison; Respondents: The Commissioners for Her Majesty’s Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
23 May 2011
Procedural Posture
VAT Appeal / Final Judgment
Outcome
Appeal allowed
Legal Topics
VAT Registration, Taxable Supplies, Business Definition, Shooting Rights, Penalty for Late Notification
Tax Law VAT VAT Registration Taxable Supplies Business Definition Shooting Rights Penalty for Late Notification

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Parties

Edward George Harrison

Appellant

The Commissioners for Her Majesty’s Revenue and Customs

Respondents

Procedural Posture

VAT Appeal / Final Judgment

Legal Issues

  1. 1 Whether appellant made taxable supplies of shooting rights
  2. 2 Whether supplies were made in course or furtherance of a business
  3. 3 Whether value of supplies exceeded VAT registration threshold

Ratio Decidendi

The appellant only supplied administration and management services to syndicates, not shooting rights; value of such services did not exceed VAT registration threshold; even if shooting rights were supplied, they were not made in course of a business but for private pleasure and social enjoyment; appellant not liable to register for VAT or pay penalty.

Court Disposition

Appeal allowed

Orders

  • Appellant not liable to register for VAT
  • VAT assessments and penalty quashed