Lifeboats – VAT zero rating

Dover_Lifeboat_City_of_London_IIIn the UK, if a charity provides rescue or assistance at sea, purchases of the following goods and services are zero-rated through the production of a zero rating certificate by the charity to the supplier quoting the correct VAT legislation:

  • any vessel for use as a lifeboat, and repair and maintenance
  • lifeboat launching and recovery equipment and repair and maintenance
  • the construction and modification of lifeboat slipways and repair and maintenance
  • spare parts and accessories for use with the above vessels, equipment and slipways and
  • equipment of a kind ordinarily installed, incorporated or used in a lifeboat.

Royal National Lifeboat Institution v HM Revenue & Customs [2009] UKFTT 39 (TC) considered the scope of zero rating supplies to seagoing vessels. In particular, it looked at whether or not alterations or repair and maintenance services for lifeboat stations and other equipment met the direct needs of lifeboats. The supplies concerned three types of costs: alterations and improvements, repairs and maintenance, and other services such as dredging of harbours and maintenance of cliff hoists. The law exempts the supply of services to meet the ‘direct needs’ of a variety of vessels. A number of services under this area of the law, including the supply, repair and maintenance of vessels and equipment, are excluded.

The First-tier Tribunal noted that the needs of a lifeboat were different from those of other vessels because they were intended to go to sea at short notice and in all weather. Notwithstanding this, it found that the majority of services did not meet those direct needs. Exceptions were the maintenance, alterations and modifications of equipment in order to launch boats quickly (such as doors and launching gear) and included alterations to the lifeboat station to house a boat and associated architect’s and surveyor’s fees. Other services which also met the direct needs test included those that assist the boat to get to sea quickly, such as dredging of channels and maintaining slipways. It was also deemed that because the crews needed to be sufficiently trained, any training provided by third parties was also included.

See also information about the exemption from Insurance Premium Tax for lifeboats and lifeboat equipment.

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