1) This document discusses various tax issues that can arise for shooting activities on estates, including income/corporation tax if it is considered a separate trading activity rather than exempt woodlands income, PAYE and benefits-in-kind for gamekeepers and owners, business rates that may apply if not considered agriculture, VAT registration thresholds and whether activities are considered commercial, and inheritance tax relief that could be lost depending on land usage. 2) It warns that HMRC is actively investigating these tax issues for shooting estates and that one should not assume there are no potential problems, recommending getting specialist advice given the estate-specific circumstances and interactions between the different taxes. 3) Various VAT tribunal cases are also cited as examples of

1. Shooting in the Firing Line? John EndacottTax PartnerWinter Rule LLP

3. PAYE obligations / benefits in kind

4. Non-domestic rates

5. VAT

7. HMRC tax investigation project (April 2006)

8. The Shoot Project Team

10. Property trading or exempt (woodlands) income?

11. Be careful over private expenditure

12. Commercial activity – use of losses

14. Tips paid to gamekeepers

15. Gamekeeper – benefits in kind

16. Living accommodation

17. Vehicles

18. Clothing, licences and gundogs

19. PSAs

21. Business rates are payable

22. 28 day planning rule on change of use

24. Standard and zero-rated supplies

25. Barter transactions

26. VAT registration threshold

27. Business splitting

29. R F Bailey (t/a Llancillo Hall Farm)

30. J O Williams

32. Agricultural / business property relief

33. Balfour case

35. Issues will be specific to your circumstances

36. Don’t assume there isn’t a problem

37. Get specialist advice