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HR Patrick and JR Patrick (TC1699)
The taxpayers a husband and wife partnership owned a farm. The business included the provision of self-catering holiday accommodation as well as a haulage operation and cattle and sheep.
In addition the wife ran a bed and breakfast (B&B) business as a sole trader from the farmhouse. The turnover was less than the VAT registration threshold.
After a VAT visit HMRC declared that the farming partnership and the B&B should be treated as a single entity. The taxpayers appealed.
The Revenue cited a number of reasons for ruling the two businesses were one for VAT purposes:
- the bank accounts for the partnership and the B&B were joint ones in the names of both taxpayers;
- the same bookkeeper was employed for both businesses;
- money was sometimes transferred from the B&B account to that of the...
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