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HMRC internal manual

VAT Business/Non-Business Manual

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HM Revenue & Customs
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Clubs and associations: football club bonds and debentures

Some football clubs have issued bonds or debentures to raise funds for pitch and stadium developments. More recently football clubs have issued bonds to refinance their debts.

These securities often give the holder additional benefits, most notably the right to purchase discounted admission tickets for matches.

In this situation, there are three possibilities:

  • the additional entitlements are so insignificant that the whole can be treated as either the issue of a security to raise finance, not a supply for VAT purposes, or a single supply of an existing security, an exempt supply;
  • the additional entitlements are so extensive that the whole is more properly a single standard-rated supply; or
  • the supply contains more than one element, and so apportionment is needed.

You will find further guidance on this at paragraph 7.4 of V1-12 Valuation if you need to apportion the supply to reflect the exempt and standard-rated elements.