Rating Report Ltd v HMRC

In Rating Report Ltd v HMRC (TC01558 – 28 November) a company (R) placed bets on sporting events on behalf of a betting syndicate. Many but not all of the members of the syndicate were shareholders in R. HMRC issued a ruling that R was required to account for VAT on its supplies to the syndicate. R appealed contending that its supplies should be treated as exempt under VATA 1994 Sch 9 Group 4 Item 1. The First-tier Tribunal rejected this contention and dismissed the appeal. Judge Connell observed that R was ‘the agent of the syndicate not an agent of the bookmaker or betting exchange which took the risk of the bets’. He held that ‘the provision of betting facilities has to be characterised by the assumption of risk. A service of an administrative or mechanical nature such as...