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EG Harrison v HMRC

Shooting syndicate

In EG Harrison v HMRC (TC01205 – 10 June) HMRC formed the opinion that an individual (H) who was a member of a farming partnership was making supplies of shooting rights in the course or furtherance of a business.

They issued a notice of compulsory registration and assessments charging VAT.

H appealed contending that he was not carrying on any business but was merely supplying administrative services to a shooting syndicate which was organised for the enjoyment of its members rather than with a view to a profit.

The First-tier Tribunal accepted this contention and allowed his appeal specifically distinguishing JO Williams (VTD 14240) where the shooting syndicate had been organised by the landowner.

Why it matters: In the JO Williams case a farmer organised a shooting syndicate...

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