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HMRC internal manual

VAT Land and Property

HM Revenue & Customs
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Fishing and shooting (Item 1c): salmon fishing in Scotland

The sale of salmon fishing rights in Scotland involves the grant of a separate heritable interest in land and is registrable in the Land Register of Scotland (previously the General Register of Sasines). This applies whether or not the rights are sold with land.

The grant of a heritable right to take salmon falls within the exception (c) to item 1 and is therefore standard rated. However, if that right is expressly conveyed together with the ownership of the land, over which the right is exercisable, then the supply is exempt, subject to the option to tax.