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HMRC internal manual

VAT Land and Property

HM Revenue & Customs
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Fishing and shooting (Item 1c): supplies made by landowners to shooting syndicates

The supply of shooting rights by the landowner to a syndicate is standard-rated. In some cases, you may find that the landowner is a gun of the syndicate and enjoys shooting free or at a reduced rate (ie does not pay a full share of syndicate expenses) in return for making a lower charge or even no charge at all, for the grant of shooting rights.

In such circumstances there is a non-monetary consideration for the shooting rights and the landowner should account for VAT on the subjective value of the supply as per the principles established by the ECJ in the Naturally Yours Cosmetics Ltd. (Case 230/87) and Empire Stores Ltd (Case 33/93). This is the explicit or implicit value of the non-monetary consideration agreed between the parties. If there is no such agreement, it is the value which the landowner attributes to the consideration (the ‘shooting days’) received, ie what it would cost the landowner to pay for the shooting day(s) as part of the syndicate.

You can find more information about non-monetary consideration in VATSC.

If the landowner’s share of the syndicate expenses is not reduced, the value of the supply of the shooting rights can be taken solely as the money paid by the syndicate for this supply. If no money at all is paid for the shooting rights and the landowner still pays a full share of the syndicate’s expenses, there is no supply for VAT purposes. Other supplies made to a syndicate by a landowner may include goods and services such as ammunition or the services of a gamekeeper for a separate consideration. These supplies are liable to VAT in the normal way.