Market leading insight for tax experts
View online issue

The Professional Golfers Association v HMRC

In The Professional Golfers Association v HMRC (TC02992 – 25 October) the Professional Golfers Association (GPA) was appealing against HMRC’s decision to deny approval under ITEPA 2003 s 344. The benefit of approval was that its members would be entitled to deduct their annual membership fees when computing their taxable earnings.

In order to fall within the ambit of s 344 the PGA had to show (inter alia) that its activities were carried on ‘otherwise than for profit’ and that its activities were ‘wholly or mainly directed’ at objects listed in the section (broadly; the dissemination of knowledge the maintenance of standards and the provision of indemnity).

The tribunal saw no difficulty with the fact that the PGA carried out commercial activities for the purpose of generating income which was ‘ploughed back’ into activities for the benefit of its members’. The fact that the benefit may be...

If you or your firm subscribes to Taxjournal.com, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
EDITOR'S PICKstar
Top