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HMRC internal manual

Business Income Manual

Meaning of trade: mutual trading and members clubs: rugby clubs: Rugby Football Union (RFU) booklet

In 1997 the RFU provided their members with a booklet setting out guidelines on mutual trading as it applied to RFU members. HMRC was consulted during the production of the booklet and accepted that it established a consistent and easily applied methodology to assist clubs in complying with their tax obligations. HMRC reserved its position as regards the detailed application of legal principles.

You should refer any case where following the RFU booklet apparently results in an outcome inconsistent with the legal principles underlying mutual trading to CTISA (Technical).