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HMRC internal manual

VAT Food

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HM Revenue & Customs
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Items benefiting from the relief: live animals: examples of the liability of particular species

Poultry / birds

Poultry covers all domestic chickens and game birds (such as pheasants and partridge) reared for food, including the supply of chicks for breeding purposes. These are zero-rated. Breeds which are essentially ornamental are standard-rated even if they are also suitable for human consumption.

The commercial breeds of duck, geese and turkey are zero-rated. The breeds and strains from them are used as and produce food for human consumption.

Racing pigeons and fancy pigeons are bred for recreational purposes and are standard-rated. Other pigeons are zero-rated.

Vaccinated chicks

These are zero-rated even if the cost of the vaccination is shown separately. However, separate supplies of vaccine or the supply of the service of vaccination is standard-rated.

Fish

All fish generally used in the UK for human consumption are zero-rated. Ornamental fish and coarse fish which are mainly used for recreational purposes are standard-rated.

Examples of coarse fish are bream, pike, carp and tench. Most coarse fish are used to stock lakes and ponds for recreational (angling) purposes. They may be occasionally eaten but they are not generally used as food in the UK.

Ornamental fish, such as Koi carp and common carp have been considered in tribunal cases. In J R Chalmers (LON/82/0099), the trader supplied ornamental fish to his customers. Koi carp is an ornamental fish and was imported from Japan by the trader. It is a very colourful fish ranging in size from about 3 inches to about 25 inches and cost from £3 for the smallest to about £2000 for the most prized koi.

The question for decision was whether koi carp falls within item 4, as live fish of a kind generally used… as food for human consumption.

The tribunal found that koi carp is not generally used as food for human consumption. The tribunal accepted that koi carp were edible but not of a kind with other fish generally used as food. Koi carp is not bred for eating but as ornamental fish; it is a very expensive fish and quite different in many respects from the common carp. Koi carp originate from Japan, whereas the common carp originated from Eastern Europe.

Fish supplied for aquarium use are usually of the ornamental variety and do not qualify for zero-rating. There is little problem in identifying this variety of fish. They are usually colourful and small, though not always so. It is highly unlikely that you will find this variety of fish being offered for sale as food.

Fish eggs from fish generally used in the UK for human consumption, whether supplied as roe or as eggs for breeding, is zero-rated. Eggs from standard-rated fish remain standard-rated.

Fish used as bait may be zero-rated only if it is fit for human consumption at the time of supply.

The following table summarizes the VAT treatment of supplies of selected live animals.

In this table, ‘SR’ means standard-rated and ‘ZR’ means zero-rated.

### Live animal ### Liability
   
Bantams: A kind of domestic chicken used for egg production. Some are used for ornamental purposes or solely to sit on other chickens’ eggs SR
Bumble bees: hire of bumble bee for pollination purposes SR
Bulls: hire for insemination purposes ZR
Cattle: all bovine animals ZR
Crustacea: lobsters, oysters, shrimps, mussels, prawns, whelks and all crustacea used for human consumption ZR
Deer (except ornamental breeds): ZR
Ducks (all commercial breeds): ZR (all ornamental breeds are SR)
Eggs (poultry and game): ZR
Fish Eggs (whether used for breeding or as food): Follows liability of the fish.
Fish used as bait: ZR (provided fish is suitable for human consumption at time of supply)
Geese (all commercial breeds): ZR (ornamental breeds are SR)
Goats: ZR
Hire of standard-rated animals: SR
Honey bees, including the hire of honey bees for pollination: ZR
Incubation services: SR
Ornamental Fish: SR
Ostriches (From 1st April 1995): ZR
Pigs: ZR (except micro pigs sold as pets which do not meet the conditions for Z/R as food and are therefore S/R)
Pigeons (except racing pigeons): ZR
Rabbits: ZR
Turkeys: ZR
Vaccinated chicks: ZR
Vaccines and the service of vaccination: vaccination of chicks SR