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Fishy business

14 June 2016
Issue: 4554 / Categories: Tax cases

Stocks Fly Fishery (TC4994)

Single or multiple supply of fishing tickets?

Anglers who wished to fish at Stocks Fly Fishery had to buy a ticket in advance. It could be a sporting (catch and return) ticket for £17.50 or a take ticket (£24) which gave them the right to keep up to five fish they caught.

The taxpayer said that it was making two supplies. One of fishing at the standard rate and another of fish for human consumption at the zero rate. It argued that the difference between the two prices should therefore be zero rated because it related to the sale of fish. HMRC disagreed saying there was a single standard-rated supply of the right to fish in the reservoir.

The taxpayer appealed.

The First-tier Tribunal said the essential feature of the transaction was fishing. This was also the main motive of anglers going to the fishery.

The judge said:

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