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HMRC internal manual

VAT Food

HM Revenue & Customs
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Items benefiting from the relief: Seeds and plants: Treatment of particular types of plant: Rootstock

The rootstock commonly used is the common thorn (although other plant types can be used) that takes the grafts of other edible or non-edible plants. The liability of rootstock depends on whether they are a means of propagation.

The industry has long accepted that all rootstock is standard-rated irrespective of whether it is used in the growing of zero-rated or standard-rated plants and trees.

However, we have agreed that cucumber and tomato rootstock can be zero-rated. These rootstock are a trade term applied to propagating material (also referred to as tubers), which are produced by the parent plant and from which new plants can be developed.