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HMRC internal manual

VAT Single Entity and Disaggregation

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HM Revenue & Customs
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Useful legal decisions: Tribunal: husband and wife cases: Salmon Tail

In Salmon Tail (MAN/1999/0213 VTD16190) we treated the appellants, who were husband and wife, as a single entity. They argued that there were two separate entities of

  • a partnership providing wet sales, and
  • a sole proprietor (one of the partners) providing catering and accommodation.

In reaching its decision, the Tribunal decided that several factors pointed towards there being one business. These included

  • the lack of a commercial relationship between the two businesses
  • the fact that the premises was funded by the partnership, with no cross-charge for use to the sole proprietor
  • there was only one insurance policy
  • the fact that no cross-charge was made for use of the facilities.