In Wrag Barn Golf & Country Club v HMRC (Upper Tribunal – 12 April) a married couple acquired a farm in 1967. In 1987 they arranged for a newly-incorporated associated company to convert part of the farmland into a golf course. In June 1990 the couple registered for VAT as a partnership and opted to tax the golf course. In February 1991 the couple entered into a partnership agreement with their two sons to operate a golf club on the course. In 2001 a VAT officer inspected the partnership records and formed the opinion that the partnership had failed to abide by its option to tax the golf course. HMRC issued a ruling that the option was irrevocable. The partnership appealed contending that the option had only been made by the couple who owned the land and did not bind the separate partnership...
