- The Appellant sells two types of Pass, the London Pass (“LP”) and the London Explorer Pass (“LEP”), both of which entitle the purchaser to enter various attractions and use certain forms of transport in London without further payment. The LP and the LEP are priced at a discount compared to the gate prices of the Attractions.
- The Appellant launched the Pass in 1999, and HMRC originally accepted it was a “face value voucher” under Value Added Taxes Act 1994 (“VATA”), Sch 10A, but later changed its view.
- The Tribunal concludes that:
- The Passes are MPVs within the meaning of VATA, Sch 10B, and their sale to customers is therefore outside the scope of VAT.
- The Passes are not only outside the scope of VAT because they are MPVs, but also because the supplies take place when the customer uses the Pass, and not when it is purchased.
Source: bailii.org
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
