Hallé Concerts Society v HMRC

In Hallé Concerts Society v HMRC [2016] UKFTT 0294 (27 April 2016) the FTT found that supplies of membership by a society for the promotion of classical music fell within the philanthropic exemption.

The society was a members’ society and members paid annual subscriptions with various rights and benefits being associated with membership. One of the benefits was the right to priority booking in advance of tickets going on open sale to the general public. The society appealed against HMRC’s refusal of a repayment claim in relation to members’ subscriptions.

The first issue was whether the grant of membership was a supply within the scope of VAT. The FTT noted that the society was granting intangible contractual rights to persons who were prepared to guarantee the liabilities of the society and to pay the annual subscription. Members paid the subscription to receive corporate rights such as the...