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Wrag Barn Golf & Country Club v HMRC

In Wrag Barn Golf & Country Club v HMRC (No. 3) (TC02802 – 2 August) a married couple acquired a farm in 1967. In 1987 they arranged for a newly-incorporated associated company to convert part of the farmland into a golf course. In June 1990 the couple registered for VAT as a partnership and opted to tax the golf course. In February 1991 the couple entered into a partnership agreement with their two sons to operate a golf club on the course. In 2001 a VAT officer inspected the partnership records and formed the opinion that the partnership had failed to abide by its option to tax the golf course. HMRC issued a ruling that the option was irrevocable. The partnership appealed contending that the option had only been made by the couple who owned the land and did not bind the separate...

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