RUFFORTH PARK LIMITED v Revenue & Customs (VAT : car boot sale pitch - whether the leasing or letting of immoveable property - whether additional services provided)

VALUE ADDED TAX-car boot sale pitch-whether the leasing or letting of immoveable property-whether additional services provided-nature of the supply-whether a licence to occupy land or a service-whether zero rated or standard rated

The hearing took place on 24 January 2022.  The form of the hearing was V (video). All parties attended remotely and the hearing was held on the Tribunal�s VHS platform. A face to face hearing was not held because of the ongoing Covid-19 situation and it was considered appropriate to hold the hearing remotely.� The documents to which we were referred are a Hearing Bundle of 205 pages and an Authorities Bundle of 441 pages. We also had the Skeleton Arguments of the Appellant and the Respondents.

Prior notice of the hearing had been published on the gov.uk website, with information about how representatives of the media or members of the public could apply to join the hearing remotely in order to observe the proceedings.� As such, the hearing was held in public.

Mr Dermot Ryder, litigator of HM Revenue and Customs� Solicitor�s Office, for the Respondents

             The assessment was made on a �best judgement� basis. Officer Clark of HMRC arrived at the amount of VAT alleged to be due from his examination of the accounting records of the Appellant. The Appellant has not disputed the amount of the assessment, if the supply were found to be standard rated.