![UT/2023/000115 - [2025] UKUT 00004 (TCC)](https://backend.juristeca.com/files/emisores/logo_ICfrj4g.png){kind=logo}
Introduction
Introduction
The Yorkshire Agricultural Society ( the “Society”) is a charity which organises and runs the annual Great Yorkshire Show. The Society considered that its supplies of admission to the show in 2016 and 2017 were exempt supplies for value added tax (“VAT”) purposes. HMRC disagreed, and refused the Society’s claim for repayment of overpaid VAT for 2016, and issued an assessment to VAT for 2017 in respect of the supplies claimed to be exempt.
The Society appealed to the First-tier Tribunal (Tax Chamber) (the “FTT”). In a decision released on 25 April 2023 (the “Decision”), the FTT allowed the Society’s appeal against both the 2016 repayment claim and the 2017 assessment. The Appellants (“HMRC”) do not appeal against the decision regarding the 2017 assessment, but now appeal the decision regarding the 2016 repayment claim.
- Heading
- Introduction
- factual background
- relevant legislation
- the decision and the grounds of appeal
- the eu law position in summary
- ground 1: item 1(b): an event “whose primary purpose is the raising of money”
- HMRC’s arguments
- Item 1(b):Approach to construction
- Discussion
- ground 2: item 1(c): an event “that is promoted as being primarily for the raising of money”
- HMRC’s arguments
- Relevant EU law principles
- Issues raised
- Is Item 1(c) ultra vires the PVD?
- A conforming interpretation of Item 1(c)
- Direct effect
- Conclusions