In this respect, a syndicate whose members simply share the cost of running the shoot should fall within the exemption but the water becomes muddy where the syndicate lets one or two days to guns who are not its members. This is common practice where the syndicate is looking to increase its income in order to reduce running costs but the benefits of doing so will backfire if, as a result, the members have to be charged VAT on their membership fee at the rate of 20 per cent.
If a shoot is being run on a commercial basis, letting days to corporate clients for example, charging VAT is understandable but it seems harsh that members of a syndicate of individuals, who are simply trying to cover the costs of their shooting activities, may also have to pay VAT.
However, from January 1 it seems the rules have been simplified so as to make it easier to qualify for the “sporting exemption” from VAT which now applies to all VAT-able supplies made by eligible bodies that enable participation in a sport, whether supplies are made to members or non members.
Having said that VAT is a complicated area of tax, particularly for Landed Estates where opting to tax land and the resultant partial exemption rules require careful consideration, but at least in the context of a shooting syndicate matters appear to have become a little more straightforward.