In Skyview Ballooning v HMRC (TC03173 – 23 December 2013) the taxpayer sold vouchers entitling their holders to hot air balloon rides (and other related goods).
The vouchers did not show their cash value on their face as they were often bought as presents. The issue was therefore whether they could be ‘face value vouchers’. If they were unless they conferred an entitlement only to one category of goods or services the normal time of supply rules were overridden and taxable supplies would be made only when the vouchers were redeemed (VATA 1994 Sch 10A).
On a purposive interpretation the tribunal held that the vouchers were ‘face value vouchers’ and were not ‘single purpose vouchers’. They entitled the holder to whatever services or goods he wished to acquire from Skyview up to the cash value of the vouchers.
Finally as the cash...