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HMRC internal manual

Business Income Manual

Meaning of trade: mutual trading and members clubs: mutual associations: specific activities: Hunt point-to-point meetings: trading?

For many years HMRC agreed not to seek to tax any profits arising from point-to-point meetings organised by Hunts and held under Master of Foxhounds Association rules. With increasing commercialisation of the events in question the agreement not to tax profits was withdrawn with effect from 1 January 1999.

This does not necessarily mean that the profits of every point-to-point are now taxable. You need to establish that the point-to-point in question is organised in such a way as to amount to the carrying on of a trade. As emphasised in BIM24045, whether a trade is being carried on is essentially a question of fact. It may be difficult to establish to the satisfaction of a Tribunal that a small-scale event that only takes place once a year over agricultural land (in contrast to organised regular commercial events run by racecourses) amounts to a trade.

Where a trade is carried on you then need to consider the deductions that are to be allowed in computing the taxable profits. In particular you will need to take into account the approach in British Legion, Peterhead Branch, Remembrance and Welcome Home Fund v CIR [1953] 35TC509 - see BIM24475. As virtually all of the work involved in organising and carrying out events is done on a voluntary and unpaid basis by Hunt members, a significant adjustment may accrue under the so-called ‘Peterhead principle’. In addition there may be expenditure on ambulance and medical personnel, police or other security staff.