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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...

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