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HMRC internal manual

VAT Business/Non-Business Manual

HM Revenue & Customs
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Clubs and associations: wildlife trusts

The VAT treatment of wildlife and naturalists’ trusts will depend upon the individual circumstances of each trust. This page of the manual covers trusts:

  • whose income is outside the scope of VAT because of the minimal benefits supplied to members; and
  • whose subscriptions are wholly taxable.

The majority, however, fall into that category of bodies for which part of the subscription can be treated as outside the scope of VAT because it is a donation.

Before attempting to reach a decision, you should look at:

  • copies of the articles or memorandum of association, constitution, rules or equivalent;
  • a copy of any application form or leaflet that promotes the body to potential members;
  • details of all membership categories;
  • details of the subscription paid by each category of member;
  • details of the benefits supplied to each category of member;
  • details of which supplies to members are also available to non members;
  • details of what non-members have to pay - if anything - for supplies that members also receive

If section 94(2)(a) of the VAT Act 1994 applies you need to consider whether there is a donational element to the subscription:

  • is the body is charitable in nature?
  • are all benefits available to both members and non-members? (See VBNB60410).

Finally you need to consider whether the activities of the body which are additional to the membership activities are business or non-business. See VBNB60410.

The following non-business activities may take place:

  • the maintenance of nature or wildlife reserves to which the public have free access;
  • the maintenance of nature or wildlife reserves to which no-one including members may be admitted;
  • producing free literature or information;
  • research work;
  • lectures, seminars, or talks, for which no entry fee is taken;
  • campaigning for support, including lobbying government.

You should also consider the information at VTUPB Trades unions and professional bodies. See also the two cases of:

• The Game Conservancy Trust; and

• Nottinghamshire Wildlife Trust

at VBNB75990.