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HMRC internal manual

VAT Food

HM Revenue & Customs
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Items benefiting from the relief: seeds and plants: held out for sale

In considering the liability of seeds and plants, it is necessary to remember that the way in which item 2 is phrased requires relief under that item to be restricted to products that are actually to be fed to animals: this is unlike item 1, which only requires a product to be of a kind used for human consumption. It is therefore possible for a fodder plant to be liable to VAT at the standard rate if it is specifically held out for sale for a non-feed purpose. The criteria by which to judge how a product is being held out for sale are covered in Notice 701/38, Seeds and plants.