In Findmypast v HMRC [2016] UKUT 17 (21 January 2016) the UT found that credits issued by a search website were face-value vouchers so that (under the legislation in effect until 10 May 2012) no VAT was due until their redemption.
Findmypast carries on the business of providing online access to genealogy and ancestry information. It owns or has licences to a number of genealogical websites. Customers can search the historical records on the website for free but some features of the website must be paid for. This can be done by subscription or by Pay As You Go (PAYG). A subscription lasts for a fixed period whilst PAYG works with the issue of vouchers. Findmypast was seeking repayment of VAT paid on unredeemed vouchers.
The UT observed that a potential customer could search the records for free and see what was available before deciding whether or...
