Commentary

V4.113D Supplies in relation to land excluded from exemption—the taking of game or fish

Part V4 Exemption, zero-rating and reduced rates

V4.113D Supplies in relation to land excluded from exemption—the taking of game or fish

V4.113D Supplies in relation to land excluded from exemption—the taking of game or fish

The grant of any interest, right or licence consisting of a right to take game or fish is excluded from exemption1. An apportionment is made to determine the supply so excluded if2:

  1.  

    (1)     the grant includes both a right to take game or fish and some other right, eg a right to occupy the land concerned, and

  2.  

    (2)     the right to take game or fish is a valuable right

HMRC has stated that a sporting right is 'valuable' if its rental value exceeds 10% of the total

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