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HMRC internal manual

VAT Charities

Lifeboats: Definition of sea rescue services

“Rescue or assistance at sea” covers not only the saving of human life or assisting other ships or boats in difficulty but can also include assistance to marine life such as beached whales.

However, the term does not cover rescue of any kind on canals, rivers, lakes, etc.

Provided that a boat is also used for sea rescue purposes its use in the following ways would not compromise its “sole use”:

  • exercises training people in rescue work, or
  • trips to prove and test a lifeboat’s seaworthiness.

Consider the following cases we have dealt with:

  1. An organisation bought a lifeboat from the RNLI and used it to support the RNLI in their rescue activities. We agreed that although the service provided by the organisation did not necessarily encompass a full range of sea rescue activities it was nevertheless the case that the boat was used solely for rescue services. Accordingly we allowed the boat to be zero-rated.
  2. An organisation requested zero-rating for a boat which it would use for the rescue of marine and human life at sea. However, the boat was also to be used as a research and educational base. This secondary use debarred the boat from zero-rating.