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HMRC internal manual

VAT Land and Property

Sports Leagues: soccer, hockey etc

Supplies by commercial organiser of sports leagues of the right to participate in a football competition or other sports league including the provision of pitch as well as league management services was seen as a single taxable supply of sporting facilities.

However, in the case of Goals Soccer Centres plc UKFTT TC02253 the Tribunal found that there were 2 supplies:

  1. a taxable supply of league management services (e.g. administering the league, supplying the equipment and referees, arranging fixtures, prizes and competitions etc) and
  2. an exempt supply of land (the pitches). Where the conditions of Note 16 to Group 1 of Schedule 9 are met.

In cases akin to the decision in Goals Soccer Centre, HMRC accepts that there are two supplies. However, in such circumstances there may only be a single price charged to the customer. Accordingly, suppliers will need to determine the value of the two different supplies in order to establish the correct amount of VAT due and the appropriate amount of tax being restricted. Whatever method that is adopted to do this, there must be sufficient documentary evidence kept to demonstrate how a business has arrived at a fair and reasonable apportionment. Further information relating to this issue can be found in VAT Valuation Manual (VATVAL).